Page
1
of
56
UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
D.
C.
20460
April
19,
2006
MEMORANDUM
SUBJECT:
Occupational
and
Residential
Exposure
Assessment
for
2­(
Thiocyanomethylthio)
benzothiazole
TCMTB.

From:
Siroos
Mostaghimi,
Ph.
D.,
Senior
Scientist
Risk
Assessment
and
Science
Support
Branch
(
RASSB)
Antimicrobials
Division
(
7510C)

To:
Mark
Hartman,
Acting
Branch
Chief
Regulatory
Management
Branch
II
Antimicrobials
Division
(
7510C)

Through:
Norm
Cook,
Chief
Risk
Assessment
and
Science
Support
Branch
(
RASSB)
Antimicrobials
Division
(
7510C)

Chemical
No:
35603
DP
Barcode:
322615
Attached
please
find
the
Occupational
and
Residential
Exposure
Assessment
RED
Chapter
for
2­(
Thiocyanomethylthio)
benzothiazole
(
TCMTB).
Page
2
of
56
EXECUTIVE
SUMMARY
This
document
is
the
Occupational
and
Residential
Exposure
Chapter
of
the
Reregistration
Eligibility
Decision
Document
(
RED)
for
2­(
Thiocyanomethylthio)
benzothiazole
(
TCMTB).
It
addresses
the
potential
risks
to
humans
that
result
from
the
use
of
this
chemical
in
occupational
and
residential
settings.

TCMTB
is
the
active
ingredient
in
numerous
types
of
products.
The
products
are
used
in
commercial/
institutional
premises,
residential
and
public
access
areas,
as
material
preservatives,
industrial
processes
and
water
systems,
and
as
wood
preservatives
(
Use
Site
Categories
III,
IV,
VII,
VIII,
and
X,
respectively).
Examples
of
uses
include
use
in
pulp
and
paper
process
water,
use
for
sapstain
control,
and
use
as
a
textile
preservative.
Products
containing
TCMTB
are
formulated
as
liquid
ready­
to­
use,
soluble
concentrate,
and
emulsifiable
liquid.
The
percentage
of
TCMTB
in
the
various
end­
use
products
ranges
from
1.0%
to
60%.

The
durations
and
routes
of
exposure
evaluated
in
this
assessment
include
short­
term
(
ST),
intermediate­
term
(
IT),
and
in
some
instances
long­
term
(
LT)
dermal
and
inhalation
exposures,
and
ST
oral
exposures.
The
ST/
IT/
LT
dermal
endpoint
is
25
mg/
kg/
day
(
target
MOE
=
100
for
ST/
IT,
300
for
LT),
based
on
a
21­
day
dermal
toxicity
study
in
rats.
The
adverse
effects
for
this
endpoint
include
decreased
body
weight
gain,
hematological
changes,
and
clinical
chemistry
changes.
For
oral
exposure
scenarios,
the
ST
endpoint
is
16
mg/
kg/
day
(
target
MOE
=
100),
based
on
a
rabbit
developmental
study
in
which
reduced
body
weight
gain
and
food
consumption
was
observed.
The
short­
and
intermediate­
term
inhalation
endpoint
of
16
mg/
kg/
day
(
target
MOE
=
100
for
ST/
IT
and
MOE=
300
for
LT)
is
also
based
on
the
same
effects
from
the
rabbit
developmental
study,
as
well
as
on
a
90­
day
rodent
study
in
which
increased
incidence
of
histopathology
of
the
stomach
was
observed,
including
inflammation,
necrosis,
and
ulceration.

This
occupational
and
residential
assessment
was
based
on
examination
of
product
labels
describing
uses
for
the
product.
It
has
been
determined
that
exposure
to
handlers
can
occur
in
a
variety
of
occupational
and
residential
environments.
Additionally,
post­
application
exposures
are
likely
to
occur
in
these
settings.
The
representative
scenarios
selected
by
the
Antimicrobials
Division
(
AD)
for
assessment
were
evaluated
using
maximum
application
rates
as
stated
on
the
product
labels.
The
representative
scenarios
are
believed
to
provide
high­
end
estimates
of
dermal,
inhalation,
and
incidental
oral
exposure.

To
assess
most
handler
risks,
AD
used
surrogate
unit
exposure
data
from
the
Chemical
Manufacturers
Association
(
CMA)
antimicrobial
exposure
study
and
the
Pesticide
Handlers
Exposure
Database
(
PHED).
Additionally,
handler
and
post­
application
exposures
resulting
from
wood
preservation
activities
were
assessed
using
surrogate
data
from
the
proprietary
study
Measurement
and
Assessment
of
Dermal
and
Inhalation
Exposures
to
Didecyl
Dimethyl
Ammonium
Chloride
(
DDAC)
Used
in
the
Protection
of
Cut
Lumber
(
Phase
III)
(
Bestari
et
al.,
1999,
MRID
455243­
04).
Because
the
study
is
proprietary,
data
compensation
needs
to
be
paid
for
use
of
these
data
in
this
exposure
assessment.
Page
3
of
56
Residential
Handler
Risk
Summary
For
the
residential
handler
dermal
and
inhalation
risk
assessment,
the
dermal
MOEs
were
slightly
below
the
target
MOE
of
100
for
painting
with
a
brush/
roller
and
are
of
concern
for
the
airless
sprayer.
The
inhalation
MOEs
were
above
the
target
MOE
of
300
for
all
scenarios.
Specifically,
the
dermal
MOEs,
which
are
less
than
the
target
MOE
include:

 
Painting,
brush/
roller:
ST
dermal
MOE
=
25
 
Painting,
airless
sprayer:
ST
dermal
MOE
=
10
The
total
MOES
were
less
than
the
target
MOE
of
100
for:

 
Painting,
brush/
roller:
ST
dermal
MOE
=
24.9
 
Painting,
airless
sprayer:
ST
dermal
MOE
=
9.8
Residential
Post­
Application/
Bystander
Risk
Summary
For
the
residential
post­
application
risk
assessment,
MOEs
are
above
the
respective
target
MOEs
for
all
scenarios
except
for
the
following:

 
Dermal
exposure
to
toddlers
contacting
treated
carpets:
ST
Dermal
MOE
=
2,
ST
Oral
MOE
=
4
 
Dermal
exposure
to
adults
contacting
treated
clothing:
ST
Dermal
MOE
<
1
using
100%
transfer
factor,
ST
Dermal
MOE
=
9
using
5%
transfer
factor.
 
Dermal
exposure
to
toddlers
contacting
treated
clothing:
ST
Dermal
MOE
<
1
using
100%
transfer
factor,
ST
Dermal
MOE
=
6
using
5%
transfer
factor.
 
Incidental
oral
exposure
to
toddlers
mouthing
treated
clothing:
ST
Oral
MOE
=
21
Occupational
Handler
Risk
Summary
For
the
occupational
handler
dermal
and
inhalation
risk
assessment,
the
MOEs
were
above
the
target
MOE
of
100
for
ST/
IT
dermal
and
inhalation
or
300
for
LT
dermal
and
inhalation
for
all
scenarios
except
for
the
scenarios
listed
below.
Tables
5.2
through
5.6
present
the
various
needs
for
PPE
and/
or
metering
pumps
to
mitigate
risks
for
each
scenario.
It
should
be
noted
that
the
baseline
(
ungloved)
dermal
MOEs
for
material
preservation
of
paints,
textiles,
adhesives,
and
metalworking
fluid
were
calculated
using
unit
exposure
values
from
the
cooling
tower
CMA
data
set
because
baseline
dermal
unit
exposures
are
not
available
for
preservative
or
metal
fluid
categories.

 
Paint
Application
 
Airless
Sprayer:
ST/
IT
Dermal
MOE
=
6
(
ungloved)
and
17
(
gloved).
 
Paint
Application
 
Paintbrush:
ST/
IT
Dermal
MOE
=
30
(
ungloved)
and
97
(
gloved)
 
Paint
Preservation
 
Liquid
Pour:
ST/
IT
Dermal
MOE
=
1
(
ungloved)
 
Paint
Preservation
 
Liquid
Pump:
ST/
IT
Dermal
MOE
=
26
(
ungloved)
 
Textile
Preservation
 
Liquid
Pour:
ST/
IT
Dermal
MOE
=
<
1
(
ungloved)
Page
4
of
56
 
Textile
Preservation
 
Liquid
Pump:
ST/
IT
Dermal
MOE
=
64
(
ungloved)
 
Cutting
Fluid
Preservation
 
Liquid
Pour:
ST/
IT
Dermal
MOE
=
11
(
ungloved)
 
Pulp
and
Paper
 
Liquid
Pump:
ST/
IT
Dermal
MOE
=
5
(
ungloved)

The
total
MOEs
were
less
than
the
target
MOE
of
100
for
the
following
exposure
scenarios:

 
Paint
Application
 
Airless
Sprayer:
MOE
=
16
 
Paint
Application
 
Paintbrush:
MOE
=
95
Occupational
Post­
Application/
Bystander
Risk
Summary
For
the
occupational
post­
application
risk
assessment,
the
MOEs
were
above
their
respective
target
MOEs,
and
therefore
not
of
concern
for
all
scenarios.

Data
Limitations
and
Uncertainties:

There
are
a
number
of
uncertainties
associated
with
this
assessment.
The
data
limitations
and
uncertainties
associated
with
the
residential
handler
and
post­
application
exposure
assessments
include
the
following:

 
Surrogate
dermal
and
inhalation
unit
exposure
values
were
taken
from
the
proprietary
Chemical
Manufacturers
Association
(
CMA)
antimicrobial
exposure
study
(
USEPA,
1999:
DP
Barcode
D247642)
or
from
the
Pesticide
Handler
Exposure
Database
(
USEPA,
1998)
(
See
Appendix
B
for
summaries
of
these
data
sources).
Most
of
the
CMA
data
are
of
poor
quality;
therefore,
AD
requests
that
confirmatory
monitoring
data
be
generated
to
support
the
values
used
in
these
assessments.

 
The
quantities
handled/
treated
were
estimated
based
on
information
from
various
sources,
including
HED's
Standard
Operating
Procedures
(
SOPs)
for
Residential
Exposure
Assessments
(
USEPA
2000
and
2001).
In
certain
cases,
no
standard
values
were
available
for
some
scenarios.
Assumptions
for
these
scenarios
were
based
on
AD
estimates
and
could
be
further
refined
from
input
from
registrants.

The
data
limitations
and
uncertainties
associated
with
the
occupational
handler
and
post­
application
exposure
assessments
include:

 
Surrogate
dermal
and
inhalation
unit
exposure
values
were
taken
from
the
proprietary
Chemical
Manufacturers
Association
(
CMA)
antimicrobial
exposure
study
(
USEPA,
1999:
DP
Barcode
D247642)
or
from
the
Pesticide
Handler
Exposure
Database
(
USEPA,
1998)
(
See
Appendix
B
for
summaries
of
these
data
sources).
Since
the
CMA
data
are
of
poor
quality,
the
Agency
requests
that
confirmatory
data
be
submitted
to
support
the
occupational
scenarios
assessed
in
this
document.
Page
5
of
56
 
Unit
exposures
are
not
available
for
some
of
the
specific
scenarios
that
are
prescribed
for
TCMTB.
These
scenarios
include
the
following:
open
loading
into
oil­
well/
field
environments
and
metering
into
cooling
water
systems
at
power
plants.

 
For
the
wood
preservative
treatment
scenarios,
DDAC
exposure
data
were
used
for
the
lack
of
TCMTB­
specific
exposure
data.
Limitations
and
uncertainties
associated
with
the
use
of
these
data
include:
 
The
assumption
was
made
that
exposure
patterns
for
workers
at
treatment
facilities
using
DDAC
would
be
similar
to
exposure
patterns
for
workers
at
treatment
facilities
using
TCMTB,
and
therefore
the
exposures
could
be
used
as
surrogate
data
for
workers
that
treat
wood
with
TCMTB.

 
For
environmental
modeling,
it
was
assumed
that
the
leaching
process
from
the
TCMTB
treated
wood
would
be
similar
to
that
of
DDAC.
However,
due
to
the
lack
of
real
data
for
TCMTB­
treated
wood,
it
is
not
possible
to
verify
this
assumption.

 
The
quantities
handled/
treated
were
estimated
based
on
information
from
various
sources,
including
HED's
Standard
Operating
Procedures
(
SOPs)
for
Residential
Exposure
Assessments
(
USEPA
2000,
and
2001),
and
personal
communication
with
experts.
In
particular,
the
use
information
for
the
pulp
and
paper
processing,
oil­
well
uses,
and
cooling
water
tower
uses
are
based
on
personal
communication
with
biocide
manufacturers
for
these
types
of
uses.
The
individuals
contacted
have
experience
in
these
operations
and
their
estimates
are
believed
to
be
the
best
available
without
undertaking
a
statistical
survey
of
the
uses.
In
certain
cases,
no
standard
values
were
available
for
some
scenarios.
Assumptions
for
these
scenarios
were
based
on
AD
estimates
and
could
be
further
refined
from
input
from
registrants.
For
example,
the
quantities
handled/
treated
for
the
application
of
TCMTB
to
the
surface
of
metal/
wood
cooling
towers
could
be
refined.

More
detailed
discussions
of
the
uncertainties
and
limitations
can
be
found
in
Sections
4.2.3
(
residential)
and
5.3
(
occupational).
Page
6
of
56
1.0
INTRODUCTION
1.1
Purpose
In
this
document,
the
Antimicrobials
Division
(
AD)
presents
the
results
of
its
review
of
the
potential
human
health
effects
of
occupational
and
residential
exposure
to
TCMTB.
This
information
is
for
use
in
EPA's
development
of
the
TCMTB
Re­
registration
Eligibility
Decision
(
RED)
Document.

1.2
Criteria
for
Conducting
Exposure
Assessments
An
occupational
and/
or
residential
exposure
assessment
is
required
for
an
active
ingredient
if
(
1)
certain
toxicological
criteria
are
triggered
and
(
2)
there
is
potential
exposure
to
handlers
(
mixers,
loaders,
applicators,
etc.)
during
use
or
to
persons
entering
treated
sites
after
application
is
complete.
For
TCMTB,
both
criteria
are
met.
Toxicological
endpoints
were
selected
for
short­,
intermediateand
long­
term
dermal,
inhalation,
and
incidental
oral
exposures
to
TCMTB.
There
is
a
significant
potential
for
exposure
in
a
variety
of
occupational
and
residential
settings.
Therefore,
risk
assessments
are
required
for
occupational
and
residential
handlers
as
well
as
for
occupational
and
residential
post­
application
exposures
that
can
occur
as
a
result
of
TCMTB
use.

In
this
document,
handler
scenarios
were
assessed
by
using
unit
exposure
data
to
estimate
occupational
and
residential
handlers'
exposures.
Unit
exposures
are
estimates
of
the
amount
of
exposure
to
an
active
ingredient
a
handler
receives
while
performing
various
handler
tasks
and
are
expressed
in
terms
of
micrograms
or
milligrams
(
1
mg
=
1,000
µ
g)
of
active
ingredient
per
pounds
of
active
ingredient
handled.
A
series
of
unit
exposures
have
been
developed
that
are
unique
for
each
scenario
typically
considered
in
assessments
(
i.
e.,
there
are
different
unit
exposures
for
different
types
of
application
equipment,
job
functions,
and
levels
of
protection).
The
unit
exposure
concept
has
been
established
in
the
scientific
literature
and
also
through
various
exposure
monitoring
guidelines
published
by
the
USEPA
and
international
organizations
such
as
Health
Canada
and
OECD
(
Organization
for
Economic
Cooperation
and
Development).

Using
surrogate
unit
exposure
data,
maximum
application
rates
from
labels,
and
EPA
estimates
of
daily
amount
handled,
exposures
and
risks
to
handlers
were
assessed.
The
exposure/
risks
were
calculated
using
the
following
equations:

Daily
Exposure:
Daily
dermal
or
inhalation
handler
exposures
are
estimated
for
each
applicable
handler
task
with
the
application
rate,
quantity
treated/
handled
in
a
day,
and
the
applicable
dermal
or
inhalation
unit
exposure
using
the
following
formula:

Daily
Exposure:
E
=
UE
x
AR
x
AT
(
Eq.
1)

Where:
E
=
Amount
(
mg
ai/
day)
deposited
on
the
surface
of
the
skin
that
is
available
for
dermal
absorption
or
amount
inhaled
that
is
available
for
inhalation
absorption;
UE
=
Unit
exposure
value
(
mg
ai/
lb
ai)
derived
from
August
1998
PHED
data
or
from
1992
CMA
data;
AR
=
Maximum
application
rate
based
on
a
logical
unit
treatment,
such
as
acres
(
A),
square
feet
(
sq.
ft.),
gallons
(
gal),
or
cubic
feet
(
cu.
ft).
Maximum
values
are
generally
used
(
lb
ai/
A,
lb
ai/
sq
ft,
lb
ai/
gal,
lb
ai/
cu
ft);
and
Page
7
of
56
AT
=
Normalized
application
area
based
on
a
logical
unit
treatment
such
as
acres
(
A/
day),
square
feet
(
sq
ft/
day),
gallons
(
gal/
day),
or
cubic
feet
(
cu
ft/
day).

Daily
Dose:
The
daily
dermal
or
inhalation
dose
is
calculated
by
normalizing
the
daily
exposure
by
body
weight
and
adjusting,
if
necessary,
with
an
appropriate
absorption
factor.
Daily
dose
was
calculated
using
the
following
formula:

Daily
Dose:
ADD
=
E
x
ABS
(
Eq.
2)
BW
Where:
ADD
=
Average
daily
dose
or
the
absorbed
dose
received
from
exposure
to
a
chemical
in
a
given
scenario
(
mg
active
ingredient/
kg
body
weight/
day);
E
=
Amount
(
mg
ai/
day)
deposited
on
the
surface
of
the
skin
that
is
available
for
dermal
absorption
or
amount
inhaled
that
is
available
for
inhalation
absorption;
ABS
=
A
measure
of
the
amount
of
chemical
that
crosses
a
biological
boundary
such
as
lungs
(%
of
the
total
available
absorbed);
and
BW
=
Body
weight
determined
to
represent
the
population
of
interest
in
a
risk
assessment
(
kg).

Margins
of
Exposure:
Non­
cancer
inhalation
and
dermal
risks
for
each
applicable
handler
scenario
are
calculated
using
a
Margin
of
Exposure
(
MOE),
which
is
a
ratio
of
the
daily
dose
to
the
toxicological
endpoint
of
concern.

Margins
of
Exposure:
MOE
=
NOAEL
or
LOAEL
(
Eq.
3)
ADD
Where:
MOE
=
Margin
of
exposure,
value
used
to
represent
risk
or
how
close
a
chemical
exposure
is
to
being
a
concern
(
unitless);
NOAEL
or
LOAEL
=
Dose
level
in
a
toxicity
study,
where
no
observed
adverse
effects
(
NOAEL)
or
where
the
lowest
observed
adverse
effects
(
LOAEL)
occurred
in
the
study;
and
ADD
=
Average
daily
dose
or
the
absorbed
dose
received
from
exposure
to
a
chemical
in
a
given
scenario
(
mg
ai/
kg
body
weight/
day).

In
addition
to
the
target
MOEs
presented
in
Table
3.2
that
were
used
for
the
analysis,
a
series
of
assumptions
and
exposure
factors
served
as
the
basis
for
completing
the
handler
risk
assessment.
Each
general
assumption
and
factor
for
both
residential
and
occupational
assessments
is
detailed
below.
Assumptions
specific
to
the
use
site
category
are
listed
in
each
separate
section
of
this
document.
The
general
assumptions
and
factors
include:

 
TCMTB
products
are
widely
used
and
have
a
large
number
of
use
patterns
that
are
difficult
to
completely
capture
in
this
document.
As
such,
AD
has
patterned
this
risk
assessment
on
a
series
of
likely
representative
scenarios
for
each
use
site
that
are
believed
by
AD
to
represent
the
vast
majority
of
TCMTB
uses.

 
Exposure
factors
used
to
calculate
daily
exposures
to
handlers
were
based
on
applicable
data,
if
available.
When
appropriate
data
were
lacking,
values
from
a
scenario
deemed
similar
were
used.

 
The
maximum
application
rates
allowed
by
labels
were
assumed.
Page
8
of
56
1.3
Chemical
Identification
Table
1.1
Chemical
Information
for
TCMTB
Common
Name:
2­(
Thiocyanomethylthio)
benzothiazole
(
TCMTB)

Chemical
Name:
2­(
Benzothiazolylthio)
methyl
thiocyanate
Other
Names:
TCMB
CAS
Number:
21564­
17­
0
OPP
Chemical
Code:
035603
Case
Number:
2625
Empirical
Formula:
C9H6N2S3
Molecular
Structure:

1.4
Physical/
Chemical
Properties
Table
1.4
shows
physical/
chemical
characteristics
that
have
been
reported
for
TCMTB.
Table
1.2.
Physical/
Chemical
Properties
of
TCMTB1
Parameter
TCMTB
Molecular
Weight
238.4
Melting
Point
150
E
C
Water
Solubility
42
mg/
L
at
25
E
C
Vapor
Pressure
3.1x10­
7
mm
Hg
at
25
E
C
1
Melting
point,
water
solubility,
and
vapor
pressure
estimated
using
PBT
Profiler,
a
screening
level
tool
(
USEPA,
2004).

2.0
USE
INFORMATION
2.1
Formulation
Types
and
Percent
Active
Ingredient
The
products
containing
TCMTB
as
the
active
ingredient
(
a.
i.)
are
formulated
as
liquid
ready­
to­
use,
soluble
concentrate,
emulsifiable
concentrate,
and
wettable
powder.
Concentrations
of
TCMTB
in
these
products
range
from
1.0%
to
60%.

2.2
Summary
of
Use
Pattern
and
Formulations
Page
9
of
56
The
Agency
determines
potential
exposures
to
handlers
of
the
product
by
identifying
exposure
scenarios
from
the
various
application
methods
that
are
plausible,
given
the
label
uses.
These
scenarios
are
identified
in
Appendix
A.
Based
on
a
review
of
product
labels,
TCMTB
is
the
active
ingredient
in
products
used
in
the
following
use
site
categories:
III
(
Commercial,
institutional
and
industrial
premises
and
equipment),
IV
(
Residential
and
public
access
premises),
VII
(
Material
Preservation),
VIII
(
Industrial
processes
and
water
systems),
and
X
(
Wood
preservatives).

From
the
scenarios
in
Appendix
A
(
Master
TCMTB
Label
List),
AD
selected
representative
exposure
scenarios
to
assess
the
labeled
uses
of
TCMTB
in
this
document.
These
scenarios
were
selected
to
be
representative
of
the
vast
majority
of
uses
and
are
believed
to
provide
high­
end
degrees
of
dermal,
inhalation,
or
incidental
ingestion
exposure.
The
representative
scenarios
assessed
in
this
document
are
shown
in
Table
4.1
(
residential)
and
Table
5.1
(
occupational).

3.0
SUMMARY
OF
TOXICITY
DATA
3.1
Acute
Toxicity
The
acute
toxicity
values
for
TCMTB
are
presented
in
Table
3.1.

Table
3.1.
Acute
Toxicity
of
TCMTB
Guideline
No.
Study
Type
MRID
#(
s)
Results
Toxicity
Category
81­
1
Acute
Oral
41583801
LD50
=
750
mg/
kg
III
81­
2
Acute
Dermal
41515401
LD50
>
2000
mg/
kg
III
81­
3
Acute
Inhalation
41640601
LC50
=
0.07
mg/
L
I
81­
4
Primary
Eye
Irritation
No
acceptable
studies;
all
show
corrosivity
I
81­
5
Primary
Skin
Irritation
41583701
Severe
erythema
at
72
hrs.
II
81­
6
Dermal
Sensitization
111991
Positive
Sensitizer
3.2
Summary
of
Toxicity
Endpoints
Table
3.2
summarizes
the
toxicological
endpoints
for
TCMTB.
Page
10
of
56
Table
3.2.
Summary
of
Toxicity
Endpoints
Selected
for
TCMTB
Exposure
Scenario
Dose
Used
in
Risk
Assessment
(
mg/
kg/
day)
Target
MOEs/
UFs
FQPA
safety
factor
for
Risk
Assessment
Study
and
Toxicological
Effects
Acute
Dietary
(
general
population
including
infants
and
children)
NOAEL(
maternal)
=
25.1
mg/
kg/
day
Target
MOE
=
100
UF
=
100
(
10x
inter­
species
extrapolation,
10x
intra­
species
variation)

FQPA
SF
=
1x
Acute
PAD
=
0.25
mg/
kg/
day
Developmental
Toxicity
Study
in
Rats
(
accession
no.
260491)

LOAEL(
maternal)
=
76.5
mg
/
kg/
day,
based
on
clinical
signs
of
toxicity
(
ventral
alopecia,
rough
coat,
dyspnea/
wheezing,
oral
discharge,
diarrhea/
loose
stool,
urine
staining,
piloerection,
and
hunched
gait).

Acute
Dietary
(
females
13­
49)
An
endpoint
for
females
13­
49
was
not
identified
in
the
available
database
for
TCMTB.
This
risk
assessment
is
not
required.

Chronic
Dietary
(
all
populations)
LOAEL
=
3.8
mg/
kg/
day
Target
MOE
=
300
UF
=
100
(
10x
inter­
species
extrapolation,
10x
intra­
species
variation)
DB
UF
=
3
(
3x
for
use
of
a
LOAEL)

FQPA
SF
=
1x
Chronic
PAD
=
0.013
mg/
kg/
day
Chronic
Toxicity
Study
in
Dogs
(
MRID
41342201)

LOAEL
=
3.8
mg/
kg/
day
(
males),
based
on
decreased
body
weight
gain,
decreased
white
cells,
monocytes,
and
plasma
ALT
in
males;
decreased
plasma
ALT
and
uterine
weight
in
females.

Incidental
Oral
Short­
and
Intermediate­
Term
(
1­
30
days;
30
days­
6
months)
NOAEL=
16
mg/
kg/
day
Target
MOE
=
100
UF
=
100
(
10x
inter­
species
extrapolation,
10x
intra­
species
variation)

FQPA
SF
=
1x
Developmental
Toxicity
Study
in
Rabbits
(
MRID
40075102)

LOAEL
=
32
mg/
kg/
day,
based
on
decreased
body
weight
gain
and
food
consumption
in
maternal
animals.

Dermal
All
Durations
(
1­
30
days;
1­
6
months;
>
6
months)
NOAEL=
25
mg/
kg/
day
Target
MOE
=
100
(
ST
and
IT)

Target
MOE
=
300
(
LT)

UF
=
100
(
10x
inter­
species
extrapolation,
10x
intra­
species
variation)

DB
UF
=
3
(
3x
for
use
of
a
subchronic
endpoint)

FQPA
SF
=
1x
21­
Day
Dermal
Toxicity
Study
in
Rats
(
MRID
41655801)

LOAEL
=
100
mg/
kg/
day,
based
on
decreased
body
weight
gain,
food
consumption,
and
hematological
and
clinical
chemistry
changes.

Inhalation
NOAEL
=
16
mg/
kg/
day
Target
MOE
=
100
(
ST
and
IT)
Developmental
Toxicity
Study
in
Rabbits
Page
11
of
56
Short­
and
Intermediate­
Term
(
1­
30
days;
1­
6
months)
UF
=
100
(
10x
inter­
species
extrapolation,
10x
intra­
species
variation)

Note:
an
additional
10x
is
necessary
for
route
extrapolation.
If
results
are
below
a
MOE
of
1,000,
a
confirmatory
inhalation
study
may
be
required
(
MRID
40075102)

LOAEL
=
32
mg/
kg/
day,
based
on
decreased
body
weight
gain
and
food
consumption
in
maternal
animals
Inhalation
Long­
Term
(>
6
months)
LOAEL
=
3.8
mg/
kg/
day
Target
MOE
=
300
(
LT)

UF
=
100
(
10x
inter­
species
extrapolation,
10x
intra­
species
variation)

Note:
an
additional
10x
is
necessary
for
route
extrapolation.
If
results
are
below
a
MOE
of
1,000,
a
confirmatory
inhalation
study
may
be
required
Chronic
Toxicity
Study
in
Dogs
(
MRID
41342201)

LOAEL
=
3.8
mg/
kg/
day
(
males),
based
on
decreased
body
weight
gain,
decreased
white
cells,
monocytes,
and
plasma
ALT
in
males;
decreased
plasma
ALT
and
uterine
weight
in
females.

Carcinogenicity
The
CPRC
concluded
that
TCMTB
should
be
classified
as
Group
C
­
possible
human
carcinogen
­
and
recommended
that
for
the
purpose
of
risk
characterization,
the
Reference
Dose
(
RfD)
approach
should
be
used
for
quantitation
of
human
risk.
This
was
based
on
statistically
significant
increases
in
tumors
in
both
sexes
of
the
Sprague­
Dawley
rat:
testicular
interstitial
cell
adenomas
in
males
and
thyroid
c­
cell
adenomas
in
females.

UF
=
uncertainty
factor,
FQPA
SF
=
special
FQPA
safety
factor,
NOAEL
=
no
observed
adverse
effect
level,
LOAEL
=
lowest
observed
adverse
effect
level,
PAD
=
population
adjusted
dose
(
a
=
acute,
c
=
chronic),
RfD
=
reference
dose,
MOE
=
margin
of
exposure,
LOC
=
Level
of
concern,
NA
=
Not
Applicable.

4.0
RESIDENTIAL
EXPOSURE
ASSESSMENT
4.1
Summary
of
Registered
Uses
Products
containing
TCMTB
can
be
used
in
paints
as
a
preservative.
Residents
may
also
be
exposed
to
items
that
have
been
treated
with
TCMTB
in
occupational
settings,
such
as
dimensional
lumber
for
decks
and
play
sets,
and
treated
textiles.
Appendix
A
presents
a
summary
of
all
exposure
scenarios
that
may
occur
in
residential
settings
based
on
examination
of
product
labels.
Table
4.1
identifies
the
representative
exposure
scenarios
assessed
in
this
document.

4.2
Residential
Exposure
The
exposure
scenarios
assessed
in
this
document
for
the
representative
uses
selected
by
AD
are
shown
in
Table
4.1.
The
table
also
shows
the
maximum
application
rate
associated
with
the
representative
use
and
the
EPA
registration
number
for
the
corresponding
product
label.
Handler
exposures
were
assessed
for
the
application
of
TCMTB­
preserved
paint.
Page
12
of
56
Post­
application
exposures
were
assessed
for
dermal
and/
or
oral
contact
with
treated
surfaces
(
textiles
and
lumber).

Table
4.1.
Representative
Uses
Associated
with
Residential
Exposure
Representative
Use
Application
Method(
s)
Exposure
Scenario
Registration
#
Application
Rate
Paint
 
Airless
sprayer
 
Paintbrush
/
Roller
ST
Handler:
adult
dermal
and
inhalation
1448­
55
0.015
a.
i.
weight
fraction
in
preserved
paint
[(
5%
product)
x
(
30%
ai)]
Carpets
 
NA1
ST
Post­
app:
child
incidental
ingestion
and
dermal
1448­
55
0.006
a.
i.
weight
fraction
in
preserved
carpet
[(
2%
product)
x
(
30%
ai)]
Wearing
treated
clothing
 
NA1
ST
Post­
app:
child
incidental
ingestion
and
dermal
1448­
55
0.006
a.
i.
weight
fraction
in
preserved
clothing
[(
2%
product)
x
(
30%
ai)]
Contacting
Preserved
Wood
 
NA1
ST
Post­
app:
child
incidental
ingestion
and
dermal
1448­
55
0.003
a.
i.
weight
fraction
in
preserved
wood
[(
1%
product)
x
(
30%
ai)]
1
The
handler
scenarios
were
not
assessed
because
application
of
TCMTB
to
carpets,
textiles,
and
wood
can
only
be
performed
by
occupational
handlers.

4.2.1
Residential
Handler
Exposures
The
residential
handler
scenarios
described
in
Table
4.1
were
assessed
to
determine
dermal
and
inhalation
exposures.
The
scenarios
were
assessed
using
PHED
data
and
Equations
1­
3
in
Section
1.2,
"
Criteria
for
Conducting
Risk
Assessment."
A
summary
of
the
PHED
data
set
is
presented
in
Appendix
B.

Unit
Exposure
Values:
Unit
exposure
values
were
taken
from
the
PHED
data
presented
in
HED's
Residential
SOPs
(
USEPA,
2000).

 
For
the
airless
sprayer
scenario,
PHED
dermal
and
inhalation
unit
exposure
values
for
a
residential
handler
applying
a
pesticide
using
an
airless
sprayer
were
used.
These
unit
ungloved
exposure
values
(
79
mg/
lb
a.
i.
for
dermal
and
0.83
mg/
lb
a.
i.
for
inhalation)
represent
a
handler
wearing
short
pants
and
a
short
sleeve
shirt,
with
no
gloves.

 
For
the
brush/
roller
scenario,
PHED
dermal
and
inhalation
unit
exposure
values
for
a
residential
handler
applying
a
pesticide
using
an
airless
sprayer
were
used.
These
unit
exposure
values
(
230
mg/
lb
a.
i.
for
dermal
and
0.284
mg/
lb
a.
i.
for
inhalation)
represent
a
handler
wearing
short
pants
and
a
short
sleeve
shirt,
with
no
gloves.

Quantity
handled/
treated:
The
quantities
handled/
treated
were
estimated
based
on
information
from
various
sources.

 
For
the
airless
sprayer
in
paint
applications,
it
is
assumed
that
15
gallons
(
or
150
lb/
day,
assuming
paint
has
a
density
of
10
lb/
gal)
of
treated
paint
will
be
used
per
day.
Page
13
of
56
 
For
the
brush/
roller
in
paint
applications,
it
is
assumed
that
2
gallons
(
or
20
lb/
day,
assuming
paint
has
a
density
of
10
lb/
gal)
of
treated
paint
will
be
used
per
day.

Duration
of
Exposure:
The
duration
of
exposure
for
most
homeowner
applications
of
paint
is
believed
to
be
best
represented
by
the
short­
term
duration
(
1
to
30
days).
The
reason
that
short
term
duration
was
chosen
to
be
assessed
is
because
the
different
handler
and
post­
application
scenarios
are
assumed
to
be
episodic,
not
daily.
In
addition,
homeowners
are
assumed
to
use
different
products
with
varying
activities,
not
exclusively
TCMTB
treated
products.

Results
The
resulting
short­
term
exposures
and
MOEs
for
the
representative
residential
handler
scenarios
are
presented
in
Table
4.2.
The
calculated
dermal
MOEs
were
below
the
target
MOE
of
100
for
both
scenarios
(
10
for
airless
sprayer
and
25
for
paintbrush).
The
inhalation
MOEs
were
above
the
target
MOE
of
300.

The
short­
term
dermal
MOEs
for
the
paintbrush
and
airless
spray
scenarios
are
below
the
short­
term
dermal
target
MOE
of
100.
The
total
MOEs
were
less
than
the
Target
MOE
of
100.

Table
4.2
Short­
Term
Residential
Handlers
Exposures
and
MOEs
Unit
Exposure
(
mg/
lb
a.
i.)
Absorbed
Daily
Dose
(
mg/
kg/
day)
e
ST
MOE
f
Exposure
Scenario
Application
Ratea
Quantity
Handled/
Treated
per
dayb
Dermalc
Inhalationd
Dermal
Inhalation
Dermal
(
Target
MOE=
100)
Inhalation
(
Target
=
100)
Total
MOE
(
Target
MOE=
100)

Painting
 
Airless
Sprayer
0.015
a.
i.
weight
fraction
150
lb/
day
79
0.83
2.54
0.0267
10
600
9.8
Painting 
Paintbrush/
Roller
0.015
a.
i.
weight
fraction
20
lb/
day
230
0.284
0.986
0.00122
25
13,000
24.9
a
Application
rates
are
the
maximum
application
rates
determined
from
EPA
registered
labels
for
TCMTB.
b
Amount
handled
per
day
values
are
estimates.
c
All
dermal
unit
exposures
represent
ungloved,
short­
sleeve
shirt,
and
short
pants
replicates.
d
No
respirator
used
by
exposed
individual.
e
Absorbed
Daily
dose
(
mg/
kg/
day)
=
[
unit
exposure
(
mg/
lb
a.
i.)
*
application
rate
(
a.
i.
weight
fraction)
*
quantity
treated
(
lb/
day)]/
Body
weight
(
70
kg).
f
MOE
=
NOAEL
/
Absorbed
Daily
Dose.
[
Where
short­
term
dermal
NOAEL
=
25
mg/
kg/
day
and
short­
term
inhalation
NOAEL
=
16
mg/
kg/
day].
Target
MOE
is
100
for
dermal
and
inhalation.

4.2.2
Residential
Post­
application
Exposures
For
the
purposes
of
this
screening
level
assessment,
post­
application
scenarios
have
been
developed
that
encompass
multiple
products,
but
still
represent
a
high
end
exposure
scenario
for
all
products
represented.
As
shown
in
Table
4.1,
representative
post­
application
scenarios
assessed
include
crawling
on
carpets,
and
wearing
treated
clothing
(
dermal
exposure
to
adults
and
children
and
incidental
oral
exposure
to
children).
Page
14
of
56
4.2.2.1
Treated
Carpets
Dermal
Exposure
to
Toddlers
from
Treated
Carpets
Exposure
Calculations
There
is
the
potential
for
dermal
exposure
to
toddlers
crawling
on
carpets
preserved
with
TCMTB.
Short­
term
risks
have
been
presented,
as
the
preservative
is
applied
only
during
the
manufacturing
of
the
carpet.

Potential
doses
are
calculated
as
follows:

PDD
=
C
x
SA
x
TR
(
Eq.
4)
BW
Where:

PDD
=
potential
daily
dose
(
mg/
kg/
day);
C
=
concentration
on
carpet
(
mg/
m2);
SA
=
surface
area
of
skin
that
contacts
the
treated
carpet
(
m2/
day);
TR
=
transferable
residue
from
carpet
to
skin
(%);
and
BW
=
body
weight
(
kg).

And
C
=
WFai
x
W
x
CF1
x
CF2
(
Eq.
5)

Where:

C
=
concentration
on
carpet
(
mg/
m2);
WFai
=
weight
fraction
of
a.
i.
in
treated
carpet
(
unitless);
W
=
face
weight
of
carpet
(
oz/
yd2);
CF1
=
unit
conversion
factor
(
28,349
mg/
oz);
and
CF2
=
unit
conversion
factor
(
1.196
yd2/
m2).

Assumptions
 
The
product
is
applied
at
a
rate
of
0.006
a.
i.
weight
fraction
to
the
carpet.

 
The
face
weight
of
the
carpet
is
assumed
to
weigh
35
oz/
yd2
(
the
face
weight
only
includes
the
carpet
fibers,
not
the
backing
materials).
The
face
weight
is
a
conservative
value
as
the
child
will
most
likely
only
be
exposed
to
the
top
portion
of
the
carpet
fibers
(
Doityourself.
com,
2005).

 
Toddlers
(
3
years
old)
were
used
to
represent
the
1
to
6
year
old
age
group.
A
body
surface
area
of
0.657
m2
and
a
body
weight
of
15
kg
were
assumed,
which
are
the
median
values
for
3
year
olds
(
USEPA,
1997).
Page
15
of
56
 
No
transferable
residue
data
were
available
that
could
be
used
to
estimate
the
transfer
of
TCMTB
from
the
carpet
to
skin
under
dry
conditions.
Therefore,
it
is
assumed
that
5%
of
the
residue
on
the
treated
carpet
is
available
for
dermal
transfer
(
USEPA,
2000
and
2001).

Results
The
calculation
of
the
dermal
dose
and
MOE
are
shown
in
Table
4.3.
The
dermal
MOE
is
below
the
target
MOE
of
100.

Table
4.3:
Dermal
Post­
Application
Exposures
and
MOEs
for
Toddlers
Contacting
Treated
Carpets
WFai
(
fraction
a.
i.
in
carpet)
W
(
face
weight
of
carpet)
(
oz/
yd2)
C
(
Conc.)
a
(
mg/
m2)
SA
(
Surface
Area
exposed)
(
m2/
day)
TR
(
transferable
residue)
PDDb
(
mg/
kg/
day)
ST
Dermal
MOEc
0.006
35.0
7,120
0.657
5%
15.6
2
a.
Concentration
on
carpet
(
mg/
cm2)
=
(
fraction
a.
i.
in
treated
carpet)
*
(
face
weight
of
carpet,
oz/
yd2)
*
(
28,349
mg/
oz)
*
(
1.196
yd2/
m2)
b
.
Absorbed
Potential
Daily
Dose
(
mg/
kg/
day)
=
[(
concentration
on
carpet,
mg/
m2)
*
(
surface
area
of
skin
in
contact
with
carpet,
m2/
day)
*
(
transferable
residue
from
carpet
to
skin)]
/
(
body
weight,
kg).
c.
Dermal
MOE
=
NOAEL
(
mg/
kg/
day)
/
Absorbed
Potential
Daily
Dose
(
mg/
kg/
day)
[
Where
short­
term
dermal
NOAEL
is
25
mg/
kg/
day].
Target
MOE
=
100.

Child
Incidental
Ingestion
Exposure
to
Treated
Carpets
Exposure
Calculations
In
addition
to
dermal
exposure,
toddlers
crawling
on
treated
carpets
will
also
be
exposed
to
TCMTB
residues
via
incidental
oral
exposure
through
hand­
to­
mouth
activity.
To
calculate
incidental
ingestion
exposure
to
these
chemicals
due
to
hand­
to­
mouth
transfer,
the
methodologies
established
in
the
Standard
Operating
Procedures
(
SOPs)
for
Residential
Exposure
Assessments
(
USEPA,
2000
and
2001)
were
used.
The
assumptions
used
are
similar
to
those
used
in
calculating
dermal
exposures
for
toddlers
crawling
on
treated
carpets.

Potential
doses
are
calculated
as
follows:

PDD
=
C
x
SA
x
ET
x
D
x
SE
x
EF
(
Eq.
6)
BW
Where:

PDD
=
potential
daily
dose
(
mg/
kg/
day);
C
=
concentration
on
carpet
(
mg/
cm2);
SA
=
surface
area
of
the
hands
mouthed
(
cm2/
event);
ET
=
exposure
time
(
hours/
day);
D
=
fraction
dislodgeable
(
unitless);
SE
=
saliva
extraction
efficiency
(%);
EF
=
exposure
frequency
(
events/
hr);
and
BW
=
body
weight
(
kg).
Page
16
of
56
And
C
=
WFai
x
W
x
CF1
x
CF2
(
Eq.
7)

Where:

C
=
concentration
on
carpet
(
mg/
cm2);
WFai
=
weight
fraction
of
a.
i.
in
treated
carpet
(
unitless);
W
=
face
weight
of
carpet
(
oz/
yd2);
CF1
=
unit
conversion
factor
(
28,349
mg/
oz);
and
CF2
=
unit
conversion
factor
(
0.00012
yd2/
cm2).

Assumptions
 
The
product
is
applied
at
a
rate
of
0.006
a.
i.
weight
fraction
to
the
carpet.
 
The
face
weight
of
the
carpet
is
assumed
to
weigh
35
oz/
yd2
(
the
face
weight
only
includes
the
carpet
fibers,
not
the
backing
materials).
The
face
weight
is
a
conservative
value
as
the
child
will
most
likely
only
be
exposed
to
the
top
portion
of
the
carpet
fibers.
(
Doityourself.
com,
2005)
 
Toddlers
(
3
years
old)
were
used
to
represent
the
1
to
6
year
old
age
group
and
are
assumed
to
weigh
15
kg,
the
median
for
male
and
female
toddlers
(
USEPA,
1997).
 
Based
on
HED's
Residential
SOP,
it
was
assumed
that
the
surface
area
used
for
each
hand­
to­
mouth
event
is
20
cm2
(
USEPA,
2000
and
2001).
 
An
exposure
time
of
8
hours
was
used,
based
on
the
total
amount
of
time
spent
indoors
for
young
children
and
subtracting
the
amount
of
time
spent
sleeping,
eating,
and
bathing
(
USEPA,
2000
and
2001).
 
The
saliva
extraction
efficiency
was
50%
(
USEPA,
2000
and
2001).
 
The
exposure
frequency
was
assumed
to
be
20
events/
hour
(
USEPA,
2000
and
2001).

Results
The
calculation
of
the
oral
doses
and
MOEs
are
shown
in
Table
4.4.
The
oral
MOE
of
5
is
below
the
target
MOE
of
100.

Table
4.4:
Incidental
Oral
Post­
application
Exposures
and
MOEs
for
Toddlers
Contacting
Treated
Carpets
C
(
Concentration
of
a.
i.
in
carpet)
a
(
mg/
cm2)
SA
(
Surface
Area
exposed)
(
cm2/
event)
ET
(
Exposure
Time)
(
hrs/
day)
D
(
Fraction
Dislodgeable)
SE
(
Saliva
Extraction
Efficiency)
EF
(
Exposure
Frequency)
(
events/
hr)
PDDb
(
mg/
kg/
day)
ST
Oral
MOEc
0.714
20.0
8.00
5%
50%
20.0
3.81
4
a.
Concentration
on
carpet
(
mg/
cm2)
=
(
fraction
a.
i.
in
treated
carpet)
*
(
face
weight
of
carpet,
oz/
yd2)
*
28,349
mg/
oz
*
0.00012
yd2/
cm2
b.
Potential
Daily
Dose
(
mg/
kg/
day)
=
[(
concentration
on
carpet,
mg/
cm2)
*
(
fraction
dislodgeable)
*
(
exposure
time,
hrs/
day)
Page
17
of
56
*
(
surface
area
of
hand,
cm2/
event)
*
(
exposure
frequency,
events/
hr)
*
(
saliva
extraction
efficiency)]/(
body
weight,
kg)
c
Oral
MOE
=
NOAEL
(
mg/
kg/
day)
/
Potential
Daily
Dose(
mg/
kg/
day)
[
Where
short­
term
incidental
oral
NOAEL
=
16
mg/
kg/
day].
Target
MOE
=
100.

4.2.2.2
Textiles
Dermal
Exposure
to
Adults
and
Toddlers
from
Contacting
Treated
Clothing
There
is
the
potential
for
dermal
exposure
to
adults
and
children
from
wearing
clothing
treated
via
factory
impregnation
of
the
chemical
as
a
preservative.
A
post­
application
assessment
assuming
no
laundering
was
conducted
as
a
conservative
measure
(
i.
e.,
the
effect
on
dislodgeable
residues
over
time
during
washing
is
not
quantifiable).
It
should
be
noted
that
it
was
assumed
that
not
all
articles
of
clothing
are
treated
with
the
TCMTB
products
or
worn
on
a
continuous
basis;
therefore,
only
short­
term
duration
exposures
were
assessed
for
the
clothing
scenarios.
It
is
believed
that
most
treated
textiles
used
in
a
residential
setting
will
result
in
exposures
occurring
over
a
short­
term
time
duration
(
1
to
30
days)
because
residents
are
assumed
to
be
exposed
to
treated
textiles
with
varying
active
ingredients,
not
exclusively
TCMTB
treated
textiles.

Exposure
Calculations
Potential
doses
are
calculated
as
follows:

PDD
=
W
x
WFai
x
CF
x
TF
(
Eq.
8)
BW
Where:

PDD
=
potential
daily
dose
(
mg/
kg/
day);
W
=
weight
of
clothing
work
(
g/
day);
WFai
=
percent
active
ingredient
in
clothing
(%);
TF
=
percent
transfer;
CF
=
conversion
factor
(
1000
mg/
µ
g);
and
BW
=
body
weight
(
kg).

And
W
=
(
SW/
SSA)
*
BSA
(
Eq.
9)

Where:

W
=
weight
of
clothing
worn
(
g/
day);
SW
=
weight
of
medium
shirt
(
g);
SSA
=
surface
area
of
medium
shirt
(
cm2);
and
BSA
=
surface
area
of
body
covered
(
cm2).

Assumptions
 
The
product
is
applied
at
a
rate
of
0.006
a.
i.
weight
fraction
to
the
clothing.
Page
18
of
56
 
The
median
surface
area
of
clothing
contacting
skin
for
a
3­
year­
old
toddler
is
5,670
cm2
(
total
body
surface
area
minus
the
head)
(
USEPA,
1997).
For
adults,
the
median
surface
area
is
16,900
cm2
(
total
body
surface
area
minus
the
head)
(
USEPA,
1997).

 
The
clothing
is
assumed
to
be
medium
weight.
For
an
adult,
a
cotton
polo
shirt
has
a
mass
of
approximately
250
g,
and
the
surface
area
covered
by
the
shirt
is
assumed
to
be
0.659
m2.
The
density
of
the
fabric
is
therefore
379
g/
cm2.
It
is
assumed
that
the
type
of
fabric
used
in
the
polo
shirt
is
used
to
cover
the
rest
of
the
body
for
both
adults
and
toddlers,
minus
the
head.
Therefore,
the
total
amount
of
fabric
worn
per
day
is
equal
to
the
density
of
the
fabric
(
379
g/
cm2)
times
the
surface
area
covered
(
5,670
cm2
for
toddlers,
16,900
cm2
for
adults),
or
215
g/
day
for
toddlers,
and
641
g/
day
for
adults.

 
Potential
doses
were
calculated
using
a
conservative
percent
transfer
of
100%,
which
assumes
that
all
residues
are
transferable
from
clothing
surfaces
to
the
skin.
In
cases
where
the
MOEs
did
not
meet
the
Agency's
target
MOE,
potential
doses
were
also
calculated
using
a
less
conservative
percent
transfer
of
5%,
which
is
based
on
the
amount
of
residue
assumed
to
be
transferable
from
carpeted
surfaces
(
USEPA,
2000
and
2001).
In
these
cases,
confirmatory
data
are
needed
to
support
the
use
of
the
lower
transfer
factor.

 
Toddlers
(
3
years
old)
are
assumed
to
weigh
15
kg.
This
is
the
mean
of
the
median
values
for
male
and
female
toddlers
(
USEPA,
1997).
For
adults,
a
body
weight
of
70
kg
has
been
assumed.
(
USEPA,
1997).

 
It
is
assumed
that
not
all
articles
of
clothing
are
treated
with
TCMTB
products
or
worn
on
a
continuous
basis;
therefore,
only
short­
term
duration
exposures
are
expected.

Results
The
calculations
of
the
short­
term
dermal
doses
and
MOEs
for
adults
and
toddlers
wearing
treated
clothing
are
shown
in
Table
4.5.
The
dermal
MOEs
for
adults
and
toddlers
are
below
the
target
MOE
of
100.
Page
19
of
56
a.
Weight
of
clothing
worn
(
g/
day)
=
(
Density
of
shirt
379
g/
cm2)
*
(
surface
area
of
body
covered,
cm2)
*
1
outfit/
day
b.
Absorbed
Potential
Daily
Dose
(
mg/
kg/
day)
=
[(
weight
of
clothing
worn,
g/
day)
*
(
weight
fraction
a.
i.
in
treated
clothing)
*
(
percent
transfer)
*
(
conversion
factor,
1000
mg/
g)]
/
(
body
weight,
kg).
c.
Dermal
MOE
=
NOAEL
(
mg/
kg/
day)
/
Absorbed
Potential
Daily
Dose
[
Where
short­
term
dermal
NOAEL
=
25
mg/
kg/
day].
Target
MOE
=
100.

Incidental
Oral
Exposure
to
Toddlers
Mouthing
Treated
Textiles
(
Clothing/
Blankets)

Exposure
Calculations
There
is
the
potential
for
incidental
oral
exposure
to
toddlers
from
mouthing
textiles
treated
with
TCMTB.

Potential
doses
are
calculated
as
follows:

PDD
=
C
x
SE
x
SA
(
Eq.
10)
BW
Where:

PDD
=
potential
daily
dose
(
mg/
kg/
day);
C
=
concentration
on
clothing
(
mg/
cm2);
SE
=
saliva
extraction
efficiency
(%);
SA
=
surface
area
mouthed
(
cm2/
day);
and
BW
=
body
weight
(
kg).

And
C
=
WFai
x
W
x
CF1
x
CF2
(
Eq.
11)

Where:

C
=
concentration
on
clothing
(
mg/
cm2);
WFai
=
weight
fraction
of
a.
i.
in
clothing
(
unitless);
W
=
weight
of
clothing
(
g/
m2);
CF1
=
unit
conversion
factor
(
1,000
mg/
g);
and
CF2
=
unit
conversion
factor
(
0.0001
m2/
cm2).
Table
4.5:
Dermal
Post­
application
Exposures
and
MOEs
for
Toddlers
and
Adults
Contacting
Treated
Clothing
Exposure
Scenario
W
(
weight
of
clothing
worn
per
day)
a
(
g/
day)
WF
(
fraction
a.
i.
in
clothing)
TF
(
percent
transfer)
PDD
(
mg/
kg/
day)
b
ST
Dermal
MOEc
100%
86.0
<
1
Toddler
215
0.006
5%
4.30
6
100%
55.0
<
1
Adult
641
0.006
5%
2.70
9
Page
20
of
56
Assumptions
 
The
product
is
applied
at
a
rate
of
0.006
a.
i.
weight
fraction
to
the
carpet.

 
The
clothing
is
assumed
to
be
medium
weight.
For
an
adult,
a
cotton
polo
shirt
has
a
mass
of
approximately
250
g,
and
the
surface
area
covered
by
the
shirt
is
assumed
to
be
0.659
m2.
The
density
of
the
fabric
is
therefore
379
g/
cm2.

 
The
saliva
extraction
efficiency
was
50%
(
USEPA,
2000
and
2001).

 
The
surface
area
of
textiles
mouthed
by
toddlers
is
100
cm2
(
HERA,
2005).

 
Toddlers
(
3
years
old)
are
used
to
represent
the
1
to
6
year
old
age
group.
For
three­
year
olds,
the
median
body
weight
is
15
kg
(
USEPA,
1997).

Results
Table
4.6
shows
the
calculation
of
the
oral
dose
and
oral
MOE
for
toddlers
mouthing
treated
textiles.
The
MOE
value
is
below
the
target
MOE
of
100.

Table
4.6:
Incidental
Oral
Exposures
and
MOEs
for
Toddlers
Wearing
Treated
Textiles
(
Clothing/
Blankets)

Weight
of
clothing
(
g/
m2)
Concentration
on
clothinga
(
mg/
cm2)
Surface
area
mouthed
(
cm2/
day)
Saliva
extraction
efficiency
Potential
daily
dose
(
mg
a.
i./
kg/
day)
Incidental
Oral
MOEc
379
0.2274
100
50%
0.758
21
a.
Concentration
on
clothing
(
mg/
cm2)
=
(
Weight
fraction
a.
i.
in
clothing,
0.006)
*
(
weight
of
clothing,
g/
cm2)
*
(
1,000
mg/
g)
*
(
0.0001
m2/
cm2)
b.
Potential
Daily
Dose
(
mg/
kg/
day)
=
(
concentration
on
clothing,
mg/
cm2)
*
(
surface
area
mouthed,
cm2/
day)
*
(
saliva
extraction
efficiency)
/
(
body
weight,
kg).
c
Oral
MOE
=
NOAEL
(
mg/
kg/
day)
/
Potential
Daily
Dose
[
Where
short­
term
incidental
oral
NOAEL
=
16
mg/
kg/
day].
Target
MOE
=
100.

4.2.3
Data
Limitations/
Uncertainties
There
are
several
data
limitations
and
uncertainties
associated
with
the
residential
handler
and
post­
application
exposure
assessments.
These
include
the
following:

 
Surrogate
dermal
and
inhalation
unit
exposure
values
were
taken
from
the
proprietary
Chemical
Manufacturers
Association
(
CMA)
antimicrobial
exposure
study
(
USEPA,
1999:
DP
Barcode
D247642)
or
from
the
Pesticide
Handler
Exposure
Database
(
USEPA,
1998)
(
See
Appendix
B
for
summaries
of
these
data
sources).
Most
of
the
CMA
data
are
of
poor
quality,
therefore,
AD
requests
that
confirmatory
monitoring
data
be
generated
to
support
the
values
used
in
these
assessments.

 
The
quantities
handled/
treated
were
estimated
based
on
information
from
various
sources,
including
HED's
Standard
Operating
Procedures
(
SOPs)
for
Residential
Exposure
Assessments
(
USEPA
2000,
and
2001).
In
certain
cases,
no
standard
values
were
Page
21
of
56
available
for
some
scenarios.
Assumptions
for
these
scenarios
were
based
on
AD
estimates
and
could
be
further
refined
from
input
from
registrants.

5.0
OCCUPATIONAL
EXPOSURE
ASSESSMENT
The
exposure
scenarios
assessed
in
this
document
for
the
representative
uses
selected
by
AD
are
shown
in
Table
5.1.
The
table
also
shows
the
maximum
application
rate
associated
with
the
representative
use
and
the
appropriate
EPA
Registration
number
for
the
product
label.
Appendix
A
(
Master
List
of
TCMTB
Products)
presents
a
summary
of
all
exposure
scenarios
that
may
occur
in
occupational
settings
based
on
examination
of
product
labels.

Potential
occupational
handler
exposure
can
occur
in
various
use
sites,
which
include:
commercial/
institutional
premises,
and
industrial
processes
and
water
systems.
Additionally,
occupational
exposure
can
occur
during
the
preservation
of
wood.
For
the
preservation
of
wood,
the
procedure
for
treatment
can
occur
in
different
ways,
such
that
multiple
worker
functions
were
analyzed.
Due
to
the
complexity
of
the
wood
preservative
analysis,
the
results
for
handler
and
post­
application
exposures
are
presented
in
a
separate
section
(
Section
5.3).

Table
5.1.
Representative
Exposure
Scenarios
Associated
with
Occupational
Exposures
to
TCMTB
Representative
Use
Method
of
Application
Exposure
Scenario
Registration
#
Application
Rate
Commercial/
Institutional
Premises
(
III)
Paint
Application
 
Airless
Sprayer
 
Paintbrush
/
Roller
ST/
IT
Handler:
Dermal
and
Inhalation
1448­
55
1.5%
a.
i.
by
weight
[(
5%
Product)
x
(
30%
ai)]

Material
Preservation
(
VII)
Paint
Preservation
 
Liquid
Pour
 
Liquid
Pump
ST/
IT
Handler:
Dermal
and
inhalation
1448­
99
1.5%
a.
i.
by
weight
[(
15%
Product)
x
(
10%
ai)]

Textile
Preservation
 
Liquid
pour
 
Liquid
pump
ST/
IT
Handler:
Dermal
and
inhalation
1448­
55
0.6%
a.
i.
by
weight
[(
2%
product)
x
(
30%
ai)]

Metal
Working
Fluid
preservation
 
Liquid
pour
 
Liquid
pump
ST/
IT/
LT
Handler:
Dermal
and
inhalation
ST
and
IT/
LT
Machinist:
dermal
and
inhalation
1448­
265
0.125%
a.
i.
by
weight
[(
1250
ppm
a.
i.)
/
1,000,000]

Industrial
processes
and
water
systems
(
Use
Category
VIII)
Page
22
of
56
Table
5.1.
Representative
Exposure
Scenarios
Associated
with
Occupational
Exposures
to
TCMTB
Representative
Use
Method
of
Application
Exposure
Scenario
Registration
#
Application
Rate
Drilling
Fluida
 
Liquid
Pour
ST/
IT
Handler:
Dermal
and
Inhalation
1448­
99
0.075%
a.
i.
by
weight
[(
0.75%
Product)
x
(
10%
ai)]

Pulp
and
Paper
 
Metered
pump
ST/
IT
Handler:
Dermal
and
Inhalation
1448­
386
0.075%
a.
i.
by
weight
[(
30
lbs
prod/
ton
paper)
x
(
5%
ai)
/
2,000
lb/
ton]
Small
process
water
systems
 
Liquid
Pour
 
Metered
Pump
ST/
IT
Handler:
Dermal
and
Inhalation
1448­
55
(
for
use
in
wastewater
systems)
9.00x10­
4
%
a.
i.
by
weight
[(
30
ppm
Product)
x
(
30%
ai)
/
1,000,000]

Wood
Preservation
(
Use
Category
X)
Non­
pressure
treatment
of
wood
and
wood
products
in
wood
treatment
facilities
Handler
Worker
Functions
 
Diptank
Operators
 
Blender/
spra
y
operators
 
Chemical
operators
Post­
Application
Worker
Functions
 
Graders
 
Trim
saw
operators
 
Clean­
up
crews
 
Construction
Workers
ST/
IT/
LT
Handler:
inhalation
ST/
IT/
LT
Post­
applicat
ion:
dermal
and
inhalation
1448­
55
0.3%
a.
i.
by
weight
[(
1%
product)
x
(
30%
ai)]

a
There
are
no
representative
unit
exposures
data
for
chemical
metering
(
i.
e.
liquid
pump)
into
secondary
recovery
oil
operations.
Since
the
volume
of
water
being
treated
in
secondary
recovery
oil
operations
is
so
large,
the
available
CMA
data
can
not
be
reliably
extrapolated.
This
is
because
CMA
data
are
based
on
activities
that
handle
much
lower
volumes
and
possibly
different
techniques.

5.1
Occupational
Handler
Exposures
The
occupational
handler
scenarios
included
in
Table
5.1
were
assessed
to
determine
inhalation
exposures.
The
general
assumptions
and
equations
that
were
used
to
calculate
occupational
handler
inhalation
risks
are
provided
in
Section
1.2,
Criteria
for
Conducting
the
Risk
Assessment.
The
majority
of
the
scenarios
were
assessed
using
CMA
data
and
Equations
1­
3.
However,
for
the
occupational
scenarios
in
which
CMA
data
were
insufficient,
other
data
and
methods
were
applied.
Page
23
of
56
Unit
Exposure
Values
(
UE):
Inhalation
unit
exposure
values
were
taken
from
the
proprietary
Chemical
Manufacturers
Association
(
CMA)
antimicrobial
exposure
study
(
USEPA,
1999b:
DP
Barcode
D247642)
or
from
the
Pesticide
Handler
Exposure
Database
(
USEPA,
1998).

$
For
the
liquid
pour
scenarios,
the
unit
exposure
depends
on
the
material
being
treated.
The
following
CMA
unit
exposures
were
available
and
used
for
the
following
scenarios:
 
Paint
preservation,
textile
preservation,
drilling
fluids:
CMA
preservative
data
(
gloved).
The
dermal
UE
is
0.135
mg/
lb
a.
i.
and
the
inhalation
unit
exposure
is
0.00346
mg/
lb
a.
i.
and
is
based
on
2
replicates.
Although
this
unit
exposure
is
based
on
minimal
replicates,
the
exposure
value
is
similar
to
the
one
found
in
PHED
for
a
similar
scenarios.
Since
no
baseline
dermal
(
ungloved)
unit
exposure
data
are
available
for
preservative
uses
in
adhesives,
paint,
or
textiles,
the
baseline
dermal
exposures
were
evaluated
using
the
cooling
tower
CMA
data
(
50.3
mg/
lb
ai).

 
Metal
working
fluid:
CMA
metal
fluid
gloved
data.
The
dermal
UE
is
0.184
mg/
lb
a.
i.
and
the
inhalation
UE
is
0.00854
mg/
lb
a.
i..
The
values
are
based
on
8
replicates
where
the
test
subjects
were
wearing
a
single
layer
of
clothing
and
chemical
resistant
gloves.
Since
no
baseline
dermal
(
ungloved)
unit
exposure
data
are
available
for
metal
working
fluid,
the
baseline
dermal
exposures
were
evaluated
using
the
cooling
tower
CMA
data
(
50.3
mg/
lb
ai).

 
Small
process
water
systems:
CMA
cooling
tower
data
(
gloved
and
ungloved).
The
dermal
and
inhalation
unit
exposures
are
10.1
and
0.450
mg/
lb
a.
i.,
respectively,
based
on
5
replicates.
The
ungloved
dermal
unit
exposure
value
is
50.3
mg/
lb
ai.

$
For
the
liquid/
metering
pump
scenarios,
the
unit
exposure
depends
on
the
material
being
treated.
The
following
CMA
unit
exposures
were
available
and
used
for
the
following
scenarios:
 
Metal
working
fluid:
CMA
metal
fluid
gloved
data.
The
dermal
UE
is
0.312
mg/
lb
a.
i.
and
the
inhalation
UE
is
0.00348
mg/
lb
a.
i.
The
values
are
based
on
2
replicates
where
the
test
subjects
were
wearing
a
single
layer
of
clothing
and
chemical
resistant
gloves.
Since
no
baseline
dermal
(
ungloved)
unit
exposure
data
are
available
for
metal
working
fluid,
the
baseline
dermal
exposures
were
evaluated
using
the
cooling
tower
CMA
data
(
0.454
mg/
lb
ai).

 
Pulp
and
paper,
cooling
water
systems:
CMA
pulp
and
paper
gloved
data
were
used.
The
dermal
and
inhalation
unit
exposures
are
0.000454
mg/
lb
ai
and
0.000265
mg/
lb
a.
i.,
respectively.
These
values
are
based
on
7
replicates
where
the
test
subjects
were
wearing
a
single
layer
of
clothing
and
chemical
resistant
gloves.
These
unit
exposures
were
used
for
the
once
through
cooling
water
system
because
no
representative
data
exists
for
the
volume
of
water
treated
in
power
plant
facilities.
Since
no
baseline
dermal
(
ungloved)
unit
exposure
data
are
available
for
metal
working
fluid,
the
baseline
dermal
exposures
were
evaluated
using
the
cooling
tower
CMA
data
(
0.454
mg/
lb
ai).
 
Paint
preservation
and
textile
preservation:
CMA
preservative
gloved
data.
The
dermal
UE
is
0.00629
mg/
lb
a.
i.
and
the
inhalation
UE
is
0.000403
mg/
lb
a.
i.
Page
24
of
56
The
values
are
based
on
two
replicates
where
the
test
subjects
were
wearing
a
single
layer
of
clothing
and
chemical
resistant
gloves.
Since
no
baseline
dermal
(
ungloved)
unit
exposure
data
are
available
for
preservative
uses
in
adhesives,
paint,
or
textiles,
the
baseline
dermal
exposures
were
evaluated
using
the
cooling
tower
CMA
data
(
0.454
mg/
lb
ai).

 
Small
process
water
systems:
CMA
cooling
tower
data.
The
dermal
UE
is
0.086
and
the
inhalation
UE
is
0.00432
mg/
lb
a.
i.,
based
on
4
replicates.
Since
no
baseline
dermal
(
ungloved)
unit
exposure
data
are
available
for
preservative
uses
in
adhesives,
paint,
or
textiles,
the
baseline
dermal
exposures
were
evaluated
using
the
cooling
tower
CMA
data
(
0.454
mg/
lb
ai).

$
For
airless
sprayer
scenarios,
the
occupational
PHED
dermal
and
inhalation
unit
exposure
values
for
airless
sprayer
application
(
PHED
scenario
23)
were
used.
The
dermal
and
inhalation
exposure
values
are
38
mg/
lb
a.
i.
and
0.83
mg/
lb
a.
i.,
respectively.

$
For
the
brush/
roller
scenario,
the
occupational
PHED
dermal
and
inhalation
unit
exposure
values
for
paintbrush
applications
were
used
(
single
layer
of
clothing).
The
dermal
and
inhalation
exposure
values
are
79
mg/
lb
a.
i.
and
0.28
mg/
lb
a.
i.,
respectively.

Quantity
handled/
treated:
The
quantity
handled/
treated
values
were
estimated
based
on
information
from
various
sources.
The
following
assumptions
were
made:

 
For
the
roller/
brush
painting
scenario,
it
was
assumed
that
50
lbs
(
approximately
5
gallons
of
paint
with
a
density
of
10
lb/
gal)
of
treated
paint
are
used.

 
For
the
airless
sprayer
in
the
painting
scenario,
it
was
assumed
that
500
lbs
(
approximately
50
gallons
of
paint
with
a
density
of
10
lb/
gal)
of
treated
paint
are
used.

 
For
the
liquid
pour
scenarios,
the
quantity
of
the
chemical
that
is
handled
depends
on
the
material
that
is
being
treated.
The
following
values
were
used
for
the
different
materials:

 
Paint:
2,000
lbs
(
approximately
200
gallons,
weight
based
on
a
density
10
lb
a.
i./
gal).

 
Textiles:
10,000
lbs
 
Metal
working
fluid:
2,502
lbs
(
approximately
300
gallons,
based
on
the
density
of
water,
8.34
lb
a.
i./
gal)

 
Drilling
fluids:
The
following
use
information
was
used
to
estimate
the
amount
of
ai
handled
per
day
during
oil­
well
activities.
Biocide
is
typically
added
directly
to
drilling
rig
mud
tanks
via
open
pouring.
Over
a
3
to
6
week
period,
while
a
13,000
ft
well
is
being
drilled,
1
to
2
drums
(
1
drum
=
42
gallons)
of
biocide
may
be
used
if
microbiological
problems
are
encountered.
Therefore,
the
short­
term
exposure
assessment
used
5.6
gallons
for
the
amount
of
biocide
handled
per
day
by
the
drilling
rig
worker
[
i.
e.,
(
2
drums
x
42
gal/
drum)
/
(
5
days/
week
x
3
weeks)
=
5.6
gal/
day].
Since
Product
#
1448­
99
has
a
density
of
8.2
lbs/
gal,
this
Page
25
of
56
corresponds
to
45.9
lb/
day.
The
intermediate­
term
exposure
assessment
used
2.8
gallons
(
22.9
lb/
day)
for
the
amount
of
biocide
handled
per
day
by
the
drilling
rig
worker
[
i.
e.,
(
2
drums
x
42
gal/
drum)
/
(
5
days/
week
x
6
weeks)
=
2.8
gal/
day].
Although
crew
changes
may
occur
in
drilling
rig
operations,
typically
a
designated
customer
representative
is
responsible
for
the
biocide
feeding.
Therefore,
one
person
would
be
involved
with
the
biocide
application
activities
on
a
daily
basis.

 
Small
process
water
systems:
Workers
in
small
systems
are
assumed
to
manually
pour
5
to
10
gallons
of
biocide
into
the
system,
but
larger
systems
would
utilize
chemical
pumps
in
order
to
save
time
and
labor
expense.
Therefore,
AD
assumed
that
workers
handle
10
gallons
of
biocide
per
day
when
making
open
pour
applications
(
or
90
lb/
day,
assuming
a
density
of
9
lb/
gal
for
the
product).

$
For
the
liquid/
metering
pump
scenarios
the
quantity
that
is
handled
depends
on
the
material
that
is
being
treated.
The
following
values
were
used
for
the
different
materials:
 
Paint:
10,000
lbs
(
approximately
1,000
gallons,
weight
based
on
a
density
of
10
lb
a.
i./
gal)

 
Textiles:
10,000
lbs
 
Metal
working
fluid:
2,502
lbs
(
approximately
300
gallons,
based
on
the
density
of
water,
8.34
lb
a.
i./
gal)

 
Pulp
and
Paper:
500
tons
of
paper
produced/
day
(
1,000,000
lbs/
day)

 
Small
process
water
systems:
AD
has
assumed
that
20,000
gallons
of
water
are
treated
daily
when
chemical
pump
applications
are
made
(
or
180,000
lb/
day,
assuming
the
product
has
a
density
of
9
lb/
gal).

Duration
of
Exposure:
The
MOEs
were
calculated
for
the
short­
and
intermediate­
term
durations
for
occupational
handlers
using
the
appropriate
endpoints
in
Table
3.2.

Exposure
Calculations
and
Results
The
resulting
inhalation
exposures
and
MOEs
for
the
representative
occupational
handler
scenarios
are
presented
in
Tables
5.2
and
5.3.
The
calculated
MOEs
as
well
as
total
MOEs
were
above
the
corresponding
target
MOEs
for
all
scenarios,
except
those
listed
below.

Dermal
MOES:

 
Paint
Application
 
Airless
Sprayer:
ST/
IT
Dermal
MOE
=
6
(
ungloved)
and
17
(
gloved).
 
Paint
Application
 
Paintbrush:
ST/
IT
Dermal
MOE
=
30
(
ungloved)
and
97
(
gloved)
 
Paint
Preservation
 
Liquid
Pour:
ST/
IT
Dermal
MOE
=
1
(
ungloved)
 
Paint
Preservation
 
Liquid
Pump:
ST/
IT
Dermal
MOE
=
26
(
ungloved)
 
Textile
Preservation
 
Liquid
Pour:
ST/
IT
Dermal
MOE
=
<
1
(
ungloved)
 
Textile
Preservation
 
Liquid
Pump:
ST/
IT
Dermal
MOE
=
64
(
ungloved)
Page
26
of
56
 
Metal
working
fluid
Preservation
 
Liquid
Pour:
ST/
IT
Dermal
MOE
=
11
(
ungloved)
 
Pulp
and
Paper
 
Liquid
Pump:
ST/
IT
Dermal
MOE
=
5
(
ungloved)

Total
MOES:

 
Paint
Application
 
Airless
Sprayer:
MOE
=
16
 
Paint
Application
 
Paintbrush:
MOE
=
95
Page
27
of
56
Table
5.2
Short­
and
Intermediate­
Term
Risks
Associated
with
Occupational
Handlers
Unit
Exposure
(
mg/
lb
a.
i.)
Absorbed
Daily
Dose
(
mg/
kg/
day)
c
MOE
d
Exposure
Scenario
Method
of
Application
Baseline
Dermala
PPEGloves
Dermalb
Inhalation
Application
Rate
(%
a.
i.

by
weight)
Quantity
Handled/

Treated
per
day
Baseline
Dermala
PPE­
Gloves
Dermalb
Inhalation
Baseline
Dermal
(
Target
MOE
=

100)
a
PPE­
Glove
Dermal
(
Target
MOE
=

100)
b
Inhalation
(
Target
MOE
=

100)
Total
MOE
(
Target
MOE=
100)

Airless
Sprayer
38.0
14.0
0.830
0.015
a.
i.

weight
fraction
500
lb/
day
4.07
1.50
0.0889
6
17
180
16
Paint
Application
Paintbrush
79.0
24.0
0.280
0.015
a.
i.

weight
fraction
50
lb/
day
0.846
0.257
0.00300
30
97
5,300
95
Liquid
Pour
50.3
0.135
0.00346
0.015
a.
i.

weight
fraction
2,000
lb/
day
21.6
0.0579
0.00149
1
430
11,000
414
Paint
Preservation
Liquid
Pump
0.454
0.00629
4.03x10­
4
0.015
a.
i.

weight
fraction
10,000
lb/
day
0.973
0.0135
0.000863
26
1900
19,000
1727
Liquid
Pour
50.3
0.135
0.00346
0.006
a.
i.

weight
fraction
10,000
lb/
day
43.1
0.116
0.00297
<
1
220
5.400
211
Textiles
Liquid
Pump
0.454
0.00629
4.03x10­
4
0.006
a.
i.

weight
fraction
10,000
lb/
day
0.389
0.00539
3.46x10­
4
64
4,600
46,000
4182
Liquid
Pour
50.3
0.184
0.00854
0.00125
a.
i.

weight
fraction
2,502
lb/
day
2.24
0.00821
3.81x10­
4
11
3,000
42,000
2800
Metal
Working
Fluid
Liquid
Pump
0.454
0.312
0.00348
0.00125
a.
i.

weight
fraction
2,502
lb/
day
0.0203
0.0139
1.56x10­
4
1,200
1,800
1.00x105
1768
Drilling
Fluids
Liquid
Pour
50.3
0.135
0.00346
0.00075
a.
i.

weight
fraction
ST
=
45.9
lb/
day
ST
=
0.0247
ST
=
6.64x10­
5
ST
=
1.70x10­
6
ST
=
1000
ST
=
380,000
ST
=
9.4x106
365235
Drilling
Fluids
Liquid
Pour
50.3
0.135
0.00346
0.00075
a.
i.

weight
fraction
IT
=
22.9
lb/
day
IT
=
0.0123
IT
=
3.31x10­
5
IT
=
8.49x10­
7
IT
=
2,000
IT
=
7.60x105
IT
=
1.9x107
730769
Pulp
and
Paper
Liquid
Pump
0.454
0.00454
2.65x10­
4
0.00075
a.
i.

weight
fraction
1,000,000
lb/
day
4.86
0.0486
0.00284
5
510
5,600
467
Small
Process
Water
Systems
Liquid
Pour
50.3
10.1
0.450
0.000009
a.
i.
weight
fraction
90
lb/
day
0.0006
0.000117
5.21x10­
6
43,000
21,000
3.1x106
20858
Page
28
of
56
Table
5.2
Short­
and
Intermediate­
Term
Risks
Associated
with
Occupational
Handlers
Unit
Exposure
(
mg/
lb
a.
i.)
Absorbed
Daily
Dose
(
mg/
kg/
day)
c
MOEd
Exposure
Scenario
Method
of
Application
Baseline
Dermala
PPEGloves
Dermal
b
Inhalation
Application
Rate
(%
a.
i.

by
weight)
Quantity
Handled/

Treated
per
day
Baseline
Dermala
PPE­
Gloves
Dermalb
Inhalation
Baseline
Dermal
(
Target
MOE
=

100)
a
PPE­
Glove
Dermal
(
Target
MOE
=

100)
b
Inhalation
(
Target
MOE
=

100)
Total
MOE
(
Target
MOE=
100)

Small
Process
Water
Systems
Liquid
Pump
0.454
0.0860
0.00432
0.000009
a.
i.
weight
fraction
180,000
lb/
day
0.0105
0.00199
0.0001
2,400
13,000
1.6x105
12023
ST
=
short­
term;
IT
=
intermediate­
term
a
Baseline
Dermal:
Long­
sleeve
shirt,
long
pants,
no
gloves.

b
PPE
Dermal
with
gloves:
baseline
dermal
plus
chemical­
resistant
gloves.

c
Absorbed
Daily
dose
(
mg/
kg/
day)
=
[
unit
exposure
(
mg/
lb
a.
i.)
*
application
rate
*
quantity
treated
/
Body
weight
(
70
kg).

d
MOE
=
NOAEL
(
mg/
kg/
day)
/
Absorbed
Daily
Dose
[
Where
ST/
IT
NOAEL
=
25
mg/
kg/
day
for
dermal
and
16
mg/
kg/
day
for
inhalation].
Page
29
of
56
5.2
Occupational
Post­
application
Exposures
5.2.1
Metal
Working
Fluids:
Machinist
There
is
a
potential
for
dermal
and
inhalation
exposure
when
a
worker
handles
treated
metal
working
fluids.
This
route
of
exposure
occurs
after
the
chemical
has
been
incorporated
into
the
metal
working
fluid
and
a
machinist
is
using/
handling
this
treated
end­
product.

Dermal
Exposures
Exposure
Calculations
A
short­
term
and
an
intermediate­
and
long­
term
exposure
estimate
were
derived
using
the
2­
hand
immersion
model
from
ChemSTEER.
The
model
is
available
at
www.
epa.
gov/
opptintr/
exposure/
docs/
chemsteer.
htm.
The
2­
hand
immersion
equation
is
as
follows:

PDR
=
SA
x
F
a.
i.
x
FT
x
FQ
(
Eq.
15)
BW
Where:

PDR
=
Potential
dose
rate
(
mg/
kg/
day);
SA
=
Surface
area
of
both
hands
(
cm2/
event);
F
a.
i.
=
Fraction
active
ingredient
in
treated
metal
working
fluid
(
unitless);
FT
=
Film
thickness
of
metal
fluid
on
hands
(
mg/
cm2);
FQ
=
Frequency
of
events
(
event/
day);
and
BW
=
Body
weight
(
kg).

Assumptions
 
The
surface
of
area
of
both
hands
is
840
cm2
(
USEPA,
1997).

 
The
body
weight
of
an
adult
is
70
kg
(
USEPA,
1997).

 
The
fraction
of
active
ingredient
in
treated
metal
working
fluid
is
0.00125.

 
For
short­,
intermediate­
and
long­
term
durations,
the
film
thickness
on
the
hands
is
1.75
mg/
cm2,
which
was
extracted
from
the
document
titled,
"
A
Laboratory
Method
to
Determine
the
Retention
of
Liquids
on
the
Surface
of
Hands."
The
film
thickness
is
based
on
a
machinist
immersing
both
hands
in
metal
working
fluid
and
then
partially
cleaning
hands
with
a
rag.
The
film
thickness
was
chosen
because
the
dermal
endpoint
for
short­,
intermediate­
and
long­
term
durations
is
based
on
systemic
effects.
Page
30
of
56
Inhalation
Exposures
Exposure
Calculations
A
screening­
level
intermediate
and
long
term
inhalation
exposure
estimate
for
treated
metal
working
fluids
has
been
developed
using
the
OSHA
PEL
for
oil
mist.
The
equation
used
for
calculating
the
inhalation
dose
is:

PDR
=
PEL
x
IR
x
F
a.
i.
x
ED
(
Eq.
16)
BW
Where:

PDR
=
Potential
dose
rate
(
mg/
kg/
day);
PEL
=
OSHA
PEL
(
mg/
m3);
IR
=
Inhalation
rate
(
m3
/
hr);
F
a.
i.
=
Fraction
active
ingredient
in
treated
metal
working
fluid
(
unitless);
ED
=
Exposure
duration
(
hrs/
day);
and
BW
=
Body
weight
(
kg).

Assumptions
 
The
high­
end
oil
mist
concentration
is
based
on
OSHA's
Permissible
Exposure
Limit
(
PEL)
of
5
mg/
m3
(
NIOSH,
1998).
 
The
fraction
active
ingredient
in
treated
metal
working
fluid
is
0.00125.
 
The
inhalation
rate
for
a
machinist
is
1.0
m3
/
hr.
 
A
machinist
is
exposed
to
the
metal
working
fluid
8
hours
a
day,
for
5
days
a
week.
 
The
body
weight
of
an
adult
is
70
kg
(
US
EPA
1997).

Dermal
and
Inhalation
Results
Table
5.3
shows
the
calculation
of
the
absorbed
daily
doses
and
MOEs
for
a
machinist
working
with
metal
working
fluids.
The
dermal
and
inhalation
MOE
values
as
well
as
total
MOEs
are
above
the
target
MOEs
for
all
durations.
Page
31
of
56
Table
5.3.
Short­,
Intermediate­,
and
Long­
Term
Risks
Associated
with
Post­
application
Exposure
to
Metal
Working
Fluids
treated
with
Preservative
(
Machinist)

Dermal
Inputs
Inhalation
Inputs
Absorbed
Daily
Dose
(
mg/
kg/
day)
MOE
Dermal
MOE
(
Target
MOE
=
100
for
ST/
IT,
300
for
LT)
c
Inhalation
MOE
(
Target
MOE
=
100
for
ST/
IT
and
300
for
LT)
d
Total
MOE
Weight
Fraction
a.
i.
in
Fluid
Hand
Surface
Area
(
cm2)
Film
thickness
(
mg/
cm2)
Frequency
(
event/
day)
OSHA
PEL
(
mg/
m3)
Inhal.
rate
(
m3/
hr)
Exposure
Duration
(
hrs/
day)
Dermala
Inhalationb
ST/
IT/
LT
ST/
IT
LT
ST/
IT
MOE=
10
0
LT
MOE=
300
0.00125
840
1.75
1
5
1
8
0.0263
0.000714
950
22,000
5300
910
806
a
Absorbed
Dermal
Daily
Dose
(
mg/
kg/
day)
=
[
fraction
a.
i.
in
treated
fluid
*
hand
surface
area*
film
thickness
(
mg/
cm2)*
Frequency
(
event/
day)]
/
Body
weight
(
70
kg).
b
Absorbed
Inhalation
Daily
Dose
(
mg/
kg/
day)
=
fraction
a.
i.
in
treated
fluid
*
OSHA
PEL
(
mg/
m3)
*
Inhalation
rate
(
m3/
hr)
*
exposure
duration
(
hr/
day)
/
body
weight
(
70
kg)
c
Dermal
MOE
=
NOAEL
(
mg/
kg/
day)
/
Absorbed
Daily
Dose
(
mg/
kg/
day)
[
Where:
ST/
IT/
LT
dermal
NOAEL
=
25
mg/
kg/
day].
d
Inhalation
MOE
=
NOAEL
(
mg/
kg/
day)
/
Absorbed
Daily
Dose
(
mg/
kg/
day)
[
Where:
ST/
IT
inhalation
NOAEL
=
16
mg/
kg/
day
and
LT
Inhalation
NOAEL
=
3.8
mg/
kg/
day].

5.2.2
Wood
Preservation
TCMTB
is
used
in
products
that
are
intended
to
preserve
wood
through
non­
pressure
treatment
methods.
It
can
be
applied
as
a
sapstain
control
to
freshly­
cut
wood,
incorporated
into
particle
board,
or
used
to
treat
wood
chips.
When
used
as
a
sapstain
control,
the
product
may
be
dipped,
sprayed,
or
impregnated
into
the
wood
via
pressure
treatment
(
up
to
0.3%
a.
i.
solution).
When
used
in
particle
board,
the
pesticide
is
incorporated
into
the
resin
or
binding
agent
(
0.3%
a.
i.,
based
on
dry
weight
of
wood).

The
proprietary
study,
"
Measurement
and
Assessment
of
Dermal
and
Inhalation
Exposures
to
Didecyl
Dimethyl
Ammonium
Chloride
(
DDAC)
Used
in
the
Protection
of
Cut
Lumber
(
Phase
III)"
(
Bestari
et
al.,
1999,
MRID
455243­
04)
identified
various
worker
functions/
positions
for
individuals
that
handle
DDAC­
containing
wood
preservatives
for
non­
pressure
treatment
application
methods
and
for
individuals
that
could
then
come
into
contact
with
the
preserved
wood.
The
worker
functions/
positions
identified
in
the
DDAC
study
are
presented
below.
It
was
assumed
that
similar
tasks
are
performed
when
handling
TCMTB
products
and
TCMTB
treated­
wood,
therefore,
these
same
functions
were
assessed
for
TCMTB.

Handler:
 
Blender/
spray
operators
are
workers
that
add
the
wood
preservative
into
a
blender/
sprayer
system
for
composite
wood
via
closed­
liquid
pumping.

 
Diptank
Operators
can
be
in
reference
to
wood
being
lowered
into
the
treating
solution
through
an
automated
process
(
i.
e.,
elevator
diptank,
forklift
diptank).
This
scenario
can
also
occur
in
a
smaller
scale
treatment
facility
in
which
the
worker
can
manually
dip
the
wood
into
the
treatment
solution.
Page
32
of
56
 
Chemical
operators
for
a
spray
box
system
consist
of
chemical
operators,
chemical
assistants,
chemical
supervisors,
and
chemical
captains.
These
individuals
maintain
a
chemical
supply
balance
along
with
flushing
and
cleaning
spray
nozzles.

Post­
application:
 
Graders,
positioned
right
after
the
spray
box,
grade
dry
lumber
by
hand
(
i.
e.
detect
faults).
In
the
DDAC
study,
graders
graded
wet
lumber;
therefore,
the
exposures
to
graders
using
TCMTB
are
worst­
case
scenarios.

 
Millwrights
repair
all
conveyer
chains
and
general
up­
keep
of
the
mill.

 
Clean­
up
crews
perform
general
cleaning
duties
at
the
mill.

 
Trim
saw
operators
operate
the
hula
trim
saw
and
consist
of
operators
and
strappers.
In
the
DDAC
study,
hula
trim
saw
operators
handled
dry
lumber.

 
Construction
workers
install
treated
plywood,
oriented
strand
board,
medium
density
fiberboard,
and
others.

As
very
little
chemical
specific
data
were
available
regarding
typical
exposures
to
TCMTB
as
a
wood
preservative,
surrogate
data
were
used
to
estimate
exposure
risks.
The
blender/
spray
operator
position
was
assessed
using
CMA
unit
exposure
data
and
the
remaining
handler
and
post­
application
positions
were
assessed
using
data
from
the
DDAC
study
(
Bestari
et
al.,
1999).
This
study
is
proprietary;
therefore,
data
compensation
needs
to
be
paid
for
use
of
these
data
in
this
exposure
assessment.

Blender/
Spray
Operators
Exposures
and
risks
to
the
composite
wood
blender/
spray
operators
were
assessed
using
Equations
1
through
3
in
Section
1.2.
The
surrogate
unit
exposures
were
taken
from
the
CMA
study
(
USEPA,
1999).
Specifically,
the
liquid
pump
preservative
unit
exposures
for
gloved
workers
were
used
in
this
assessment.
The
dermal
unit
exposure
was
0.00629
mg/
lb
ai
and
the
inhalation
unit
exposure
was
0.000403
mg/
lb
ai.
These
values
are
based
on
two
replicates
where
the
test
subjects
were
wearing
a
single
layer
of
clothing
and
chemical
resistant
gloves.
The
quantity
of
the
wood
being
treated
was
derived
from
other
wood
preservative
estimates
(
USEPA,
2004)
for
the
amount
of
wood
slurry
treated
because
no
chemical
specific
data
were
available
for
TCMTB.
It
was
assumed
that
batches
of
wood
slurry
are
treated
in
10,000
gallon
tanks,
and
that
eight
batches
of
wood
slurry
are
treated
per
day
(
one
per
hour
for
an
8­
hr
work
shift).
Additionally,
it
was
assumed
that
each
batch
requires
3,000
gallons
of
preservatives
and
the
remainder
volume
of
the
tank
consists
of
wood
slurry
(
7,000
gallons
of
wood
slurry
per
batch).
Since
wood
chips
have
a
density
of
approximately
380
kg/
m3
(
SIMetric,
2005),
the
total
amount
of
wood
slurry
treated
per
day
would
be
178,000
lbs
(
8
batches/
day
*
7,000
gallons/
batch
*
0.003785
m3/
gallon
*
380
kg/
m3
*
2.2
lb/
kg).
The
assumptions
used
for
batch
sizes
and
the
quantity
of
preservative
needed
are
consistent
with
an
assessment
performed
previously
by
the
EPA.
For
this
assessment,
an
application
rate
of
0.003
TCMTB
w/
w
was
used.
Page
33
of
56
Table
5.4
provides
the
short­
and
intermediate­
term
doses
and
MOEs
for
the
workers
adding
the
preservative
to
the
wood
slurry.
All
MOEs
are
above
the
target
MOE
of
100
for
ST/
IT
dermal
and
inhalation
and
above
300
for
LT
dermal
and
inhalation
exposures.

Table
5.4.
Short­,
Intermediate­,
and
Long­
term
Exposures
and
MOEs
for
Wood
Preservative
Blender/
Spray
Operators
Absorbed
Daily
Dosee
(
mg/
kg/
day)
MOEf
Dermal
Inhalation
Total
MOE
Dermal
Unit
Exposurea
(
mg/
lb
ai)
Inhalation
Unit
Exposureb
(
mg/
lb
ai)
App.
Rate
c
(
fraction
ai
in
solution/

day)
Wood
Slurry
Treatedd
(
lb/
day)
Dermal
Inhal.
ST/
IT/
LT
ST/
IT
LT
ST/
IT
LT
Occupational
Handler
0.00629
4.03x10­
4
0.00300
1.78x105
0.0480
0.0030
7
520
5200
1200
478
364
ST
=
Short­
term
duration;
IT
=
Intermediate­
term
duration;
and
LT
=
long­
term.
a.
Dermal
unit
exposure:
Single
layer
clothing
with
chemical
resistant
gloves.
b.
Inhalation
unit
exposure:
Baseline.
c.
The
maximum
application
rate
for
the
"
immersion"
application
method
is
a
solution
containing
0.3%
a.
i.
d.
Wood
slurry
treated
=
(
8
batches/
day
*
7,000
gallons/
batch
*
0.003785
m3/
gallon
*
380
kg/
m3
*
2.2
lb/
kg)
e.
Absorbed
Daily
Dose
=
unit
exposure
(
mg/
lb
ai)
x
App
Rate
(
fraction
ai/
day)
x
Quantity
treated
(
lb/
day)
/
BW
(
70
kg)
f.
MOE
=
NOAEL
(
mg/
kg/
day)/
Daily
dose
[
Where
dermal
ST/
IT/
LT
NOAEL
=
25
mg/
kg/
day,
ST/
IT
inhalation
NOAEL
=
16
mg/
kg/
day,
and
LT
inhalation
NOAEL
=
3.8
mg/
kg/
day].
Target
MOE
is
100
for
ST/
IT
dermal
exposures
and
300
for
LT
dermal
and
100
for
ST/
IT
and
300
for
LT
inhalation
exposures.

Chemical
Operators,
Graders,
Millwrights,
Clean­
up
Crews,
and
Trim
Saw
Operators
Exposures
to
chemical
operators,
graders,
millwrights,
trim
saw
operators,
and
clean­
up
crews
were
assessed
using
surrogate
data
from
the
DDAC
study
(
Bestari
et
al.,
1999).
The
DDAC
study
examined
individuals
=

exposure
to
DDAC
while
working
with
antisapstains
and
performing
routine
tasks
at
11
sawmills/
planar
mills
in
Canada.
Dermal
and
inhalation
exposure
monitoring
data
were
gathered
for
each
job
function
of
interest
using
dosimeters
and
personal
sampling
tubes.
Dosimeters
and
personal
air
sampling
tubes
were
analyzed
for
DDAC.
Exposure
data
for
individuals
performing
the
same
job
functions
were
averaged
together
to
determine
job
specific
averages.
Monitoring
was
conducted
using
2
trim
saw
workers,
13
grader
workers,
11
chemical
operators,
3
millwrights,
and
6
clean­
up
staff.

The
individual
dermal
and
inhalation
exposures
from
the
DDAC
study
are
presented
in
Table
C­
1
in
Appendix
C.
To
determine
TCMTB
exposures,
the
average
DDAC
exposures
measured
on
individuals
(
in
terms
of
total
mg
DDAC)
were
multiplied
by
a
modification
factor
of
0.00375
to
account
for
the
difference
in
percent
active
ingredient
between
TCMTB
and
DDAC
(
3%
TCMTB
in
the
wood
preservative
product
versus
80%
DDAC
in
the
comparative
wood
preservative
product).
The
lb
ai
handled
by
each
person
or
the
%
ai
in
the
treatment
solution
were
not
provided
for
these
worker
functions.

The
following
equation
was
used
to
calculate
daily
dose
for
TCMTB:

Daily
Dose
=
DDAC
UE
x
CR
x
AB
(
Eq.
17)
BW
Page
34
of
56
Where:

DDAC
UE
=
DDAC
dermal
or
inhalation
unit
exposure
(
mg/
day);
CR
=
Conversion
ratio
(
3%
TCMTB
/
80%
DDAC);
AB
=
Absorption
factor
(
100%
for
dermal
and
inhalation);
and
BW
=
Body
weight
(
70
kg).

In
using
this
methodology,
the
following
assumptions
were
made:

 
DDAC
and
TCMTB
end­
use
products
will
be
used
in
similar
quantities.

 
The
procedures
for
applying
both
chemicals
are
similar.

 
The
limits
of
detections
(
LOD)
for
inhalation
residues
from
chemical
operators,
graders,
mill
wrights,
and
clean­
up
staff
replicates
were
not
provided
in
the
DDAC
report.
For
lack
of
better
data,
it
was
assumed
that
the
inhalation
LODs
for
these
worker
positions
are
equal
to
the
LOD
of
the
diptank
operator
replicates
(
5.6
Fg).
For
all
measurements
below
the
air
concentration
associated
with
this
detection
limit,
half
the
detection
limit
was
used.
The
dermal
LOD
for
all
operators
is
also
5.6
Fg.

 
In
the
DDAC
study,
dermal
exposures
to
hands
were
measured
separately
from
the
rest
of
the
body.
For
each
replicate,
the
body
dose
measurements
and
hand
dose
measurements
were
summed
for
a
total
dermal
dose.

 
Air
concentrations
were
reported
in
the
DDAC
study.
To
convert
air
concentrations
(
Fg/
m3)
into
terms
of
inhalation
unit
exposure
(
mg/
day),
the
air
concentrations
were
multiplied
by
an
inhalation
rate
of
1.0
m3/
hr
for
light
activity
(
EPA
1997),
a
sample
duration
of
8
hrs/
day,
and
a
conversion
factor
of
1
mg/
1000
µ
g.
Table
C­
1
in
Appendix
C
presents
the
inhalation
and
dermal
DDAC
exposures.

 
Average
DDAC
dermal
and
inhalation
exposures
were
multiplied
by
a
conversion
ratio
of
0.00375
to
account
for
the
differences
in
TCMTB
and
DDAC
concentrations
[(
3%
TCMTB
/
80%
DDAC)].

Table
5.5
provides
the
short­,
intermediate­,
and
long­
term
doses
and
MOEs
for
chemical
operators,
graders,
millwrights,
clean­
up
crews,
and
trim
saw
operators.
For
all
worker
functions,
the
inhalation
MOEs
are
above
the
corresponding
target
MOEs
for
ST/
IT/
LT
durations,
and
therefore
are
not
of
concern.
For
all
worker
functions,
the
dermal
MOEs
are
above
the
target
MOE
of
100
for
ST/
IT/
LT
durations.
The
total
MOEs
were
also
above
the
target
MOEs
for
all
durations.
Page
35
of
56
Table
5.5.
Short­,
Intermediate­
and
Long­
Term
Exposures
and
MOEs
for
Wood
Preservative
Chemical
Operators,
Graders,
Trim
Saw
Operators,
and
Clean­
Up
Crews
Absorbed
Daily
Dosesd
(
mg/
kg/
day)
MOEse
Dermal
Inhalation
Total
MOE
Exposure
Scenarioa
(
number
of
volunteers)
Dermal
UEb
(
mg/
day)
Inhalation
UEb
(
mg/
day)
Conversion
Ratioc
Dermal
Inhalation
ST/
IT/
LT
ST/
IT
LT
ST/
IT
LT
Occupational
Handler
Chemical
Operator
(
n=
11)
9.81
0.0281
0.00375
5.25x10­
4
1.50x10­
6
48,000
1.10x107
2.50x106
47790
47095
Occupational
Post­
application
Grader
(
n=
13)
3.13
0.0295
0.00375
1.68x10­
4
1.58x10­
6
1.50x105
1.00x107
2.40x106
147783
141176
Trim
Saw
(
n=
2)
1.38
0.0610
0.00375
7.39x10­
5
3.24x10­
6
3.40x105
4.90x106
1.20x106
317940
264935
Millwright
(
n=
3)
12.8
0.0570
0.00375
6.86x10­
4
3.05x10­
6
36,000
5.20x106
1.20x106
35752
34951
Clean­
Up
(
n=
6)
55.3
0.600
0.00375
0.00296
3.24x10­
5
8,400
4.90x105
1.20x105
8258
7850
ST
=
Short­
term
duration;
IT
=
Intermediate­
term
duration;
and
LT
=
long­
term
a.
The
exposure
scenario
represents
a
worker
wearing
short
sleeve
shirts,
cotton
work
trousers,
and
cotton
glove
dosimeter
gloves
under
chemical
resistant
gloves.
Volunteers
were
grouped
according
to
tasks
they
conducted
at
the
mill.

b.
Dermal
and
inhalation
unit
exposures
are
from
Bestari
et
al
(
1999).
Refer
to
Table
C­
1
in
Appendix
C
for
the
calculation
of
the
dermal
and
inhalation
exposures.
Inhalation
exposure
(
mg/
day)

was
calculated
using
the
following
equation:
air
concentration
(
Fg/
m3)
x
inhalation
rate
(
1.0
m3/
hr)
x
sample
duration
(
8
hr/
day)
x
unit
conversion
(
1
mg/
1000
Fg).
The
inhalation
rate
is
from
USEPA,
1997.

c.
Conversion
Ratio
=
0.3%
TCMTB
/
80%
DDAC
d.
Absorbed
Daily
dose
(
mg/
kg/
day)
=
exposure
(
mg/
day)
*
conversion
ratio
(
0.00375)
*
absorption
factor
(
100%
for
dermal
and
inhalation)/
body
weight
(
70
kg).

e.
MOE
=
NOAEL
(
mg/
kg/
day)/
Daily
dose
[
Where
ST/
IT/
LT
dermal
NOAEL
=
25
mg/
kg/
day,
ST/
IT
NOAEL
for
inhalation
is
16
mg/
kg/
day
and
LT
NOAEL
for
inhalation
is
3.8
mg/
kg/
day].

Target
MOE
is
100
for
ST/
IT
dermal
and
inhalation
exposures
and
300
for
LT
dermal
and
inhalation
exposures.
Page
36
of
56
Diptank
Operators
Exposures
to
diptank
operators
were
also
assessed
using
surrogate
data
from
the
DDAC
study
(
Bestari
et
al.,
1999).
The
diptank
scenario
assessment
was
conducted
differently
than
for
the
other
job
functions
because
the
concentration
of
DDAC
in
the
diptank
solution
was
provided.
The
exposure
data
for
diptank
operators
wearing
gloves
were
converted
into
A
unit
exposures
@

in
terms
of
mg
a.
i.
for
each
1%
of
concentration
of
the
product.
The
calculation
of
the
dermal
and
inhalation
unit
exposures
(
2.99
and
0.046
mg/
1%
solution,
respectively)
is
presented
in
Table
C­
2
in
Appendix
C.
The
air
concentrations
presented
in
the
DDAC
study
were
converted
to
unit
exposures
using
an
inhalation
rate
of
1.0
m3/
hr
(
light
activity)
and
a
sample
duration
of
8
hrs/
day.

The
following
equations
are
used
to
estimate
dermal
and
inhalation
handler
exposure:

Daily
Dose
=
DDAC
UE
x
AI
x
AB
(
Eq.
18)
BW
Where:

DDAC
UE
=
DDAC
dermal
unit
exposure
(
mg/
1%
in
solution);
AI
=
AI
(
30%
ai
in
solution/
day);
AB
=
Absorption
factor
(
100%
for
dermal
and
inhalation);
and
BW
=
Body
weight
(
70
kg).

Table
5.6
provides
the
short­
term
and
the
intermediate­
and
long­
term
doses
and
MOEs
for
diptank
operators.
All
dermal
and
inhalation
MOES
s
as
well
as
otal
MOEs
were
above
the
corresponding
target
MOEs
and
are
therefore
not
of
concern.
Page
37
of
56
Table
5.6.
Short­,
Intermediate­,
and
Long­
Term
Exposures
and
MOEs
for
Diptank
Operator
Absorbed
Daily
Dosesc
(
mg/
kg/
day)
MOEsd
Dermal
Inhalation
Total
MOE
Exposure
Scenarioa
(
number
of
replicates)
Dermal
Unit
Exposureb
(
mg
DDAC/
1%

solution)
Inhalation
Unit
Exposureb
(
mg
DDAC/
1%

solution)
App
Rate
(
fraction
a.
i.
in
solution/

day)
c
Dermal
Inhalation
ST/
IT/
LT
ST/
IT
LT
ST/
IT
LT
Occupational
Handler
Dipping,

with
gloves
(
n=
7)
2.99
0.0460
0.300
0.0128
1.98x10­
4
1,900
81000
19000
1856
1727
ST
=
Short­
term
duration;
IT
=
Intermediate­
term
duration;
and
LT
=
long­
term.

a.
The
exposure
scenario
represents
a
worker
wearing
long­
sleeved
shirts,
cotton
work
trousers,
and
gloves.
Gloves
were
worn
only
when
near
chemical,
not
when
operating
diptank
b.
Dermal
and
inhalation
unit
exposures
are
from
DDAC
study
(
MRID
455243­
04).
Refer
to
Table
C­
2
in
Appendix
C
for
the
dermal
and
inhalation
unit
exposure
calculations.
Inhalation
exposure
(
mg)
was
calculated
using
the
following
equation:
Air
concentration
(
mg/
m3)
x
Inhalation
rate
(
1.0
m3/
hr)
x
Sample
Duration
(
8
hr).
The
inhalation
rate
is
from
USEPA,
1997.

c.
A
30%
ai
TCMTB
solution
was
used.

d.
Absorbed
Daily
dose
(
mg/
kg/
day)
=
unit
exposure
(
mg/
1%
ai
solution)
*
percent
active
ingredient
in
solution
/
body
weight
(
70
kg).

e.
MOE
=
NOAEL
(
mg/
kg/
day)/
Daily
dose
[
Where
ST/
IT/
LT
dermal
NOAEL
=
25
mg/
kg/
day,
ST/
IT
inhalation
NOAEL
=
16
mg/
kg/
day,
and
LT
inhalation
NOAEL
3.8
mg/
kg/
day].
Target
MOE
is
100
for
ST/
IT
dermal
and
inhalation
exposures
and
300
for
LT
dermal
and
inhalation
exposures.
Page
38
of
56
Construction
workers
Not
enough
data
exists
to
estimate
the
amount
of
exposure
associated
with
construction
workers
who
install
treated
wood.
In
particular,
values
for
the
transfer
coefficient
associated
with
a
construction
worker
handling
the
wood
could
not
be
determined.
However,
it
is
believed
that
the
construction
worker
using
a
trim
saw
will
have
larger
dermal
and
inhalation
exposures
than
the
installer,
due
to
the
amount
of
sawdust
generated
and
the
greater
amount
of
hand
contact
that
would
be
necessary
to
handle
the
wood
when
using
a
saw
compared
to
installing
the
wood.

5.3
Data
Limitations/
Uncertainties
There
are
several
data
limitations
and
uncertainties
associated
with
the
occupational
handler
and
post­
application
exposure
assessments.
These
include:

 
Surrogate
dermal
and
inhalation
unit
exposure
values
were
taken
from
the
proprietary
Chemical
Manufacturers
Association
(
CMA)
antimicrobial
exposure
study
(
USEPA,
1999b:
DP
Barcode
D247642)
or
from
the
Pesticide
Handler
Exposure
Database
(
USEPA,
1998)
(
See
Appendix
B
for
summaries
of
these
data
sources).
Since
the
CMA
data
are
of
poor
quality,
the
Agency
requests
that
confirmatory
data
be
submitted
to
support
the
occupational
scenarios
assessed
in
this
document.

 
Unit
exposures
are
not
available
for
some
of
the
specific
scenarios
that
are
prescribed
for
TCMTB.
These
scenarios
include
the
following:
open
loading
into
oil­
well/
field
environments
and
metering
into
cooling
water
systems
at
power
plants.

 
The
CMA
data
used
for
oil­
well
uses
are
based
on
open
pouring
of
a
material
preservative.
Although
these
data
are
only
represented
by
2
replicates
each,
the
exposure
values
are
similar
to
open
loading
of
pesticides
in
PHED.
Furthermore,
there
are
no
representative
unit
exposure
data
for
chemical
metering
into
secondary
recovery
oil
operations.
Since
the
volume
of
water
being
treated
in
secondary
recovery
operations
is
so
large,
the
available
CMA
data
can
not
be
reliably
extrapolated
because
they
are
based
on
activities
that
handle
much
lower
volumes
and
possibly
different
techniques.
Therefore,
it
was
assumed
that
if
the
open
pour
handling
activities
for
the
other
oil
well
operations
resulted
in
MOEs
that
are
not
of
concern,
then
the
MOEs
for
the
closed
system
chemical
metering
into
secondary
recovery
operations
would
also
be
not
of
concern.
AD
requests
that
confirmatory
data
be
conducted
to
show
that
this
is
accurate.

 
The
CMA
data
used
for
cooling
water
systems
at
power
plants
are
based
on
closed
metering
for
pulp
and
paper.
The
pulp
and
paper
unit
exposures
were
deemed
more
appropriate
than
the
cooling
water
tower
data
because
of
the
large
volume
of
water
treated
in
cooling
water
systems
at
power
plants.
However,
the
CMA
data
for
pulp
and
paper
does
not
reliably
represent
the
volume
of
water
treated
and
the
possibly
different
techniques
used
to
treat
the
water.

 
For
the
wood
preservative
treatment
scenarios,
DDAC
exposure
data
were
used
for
the
lack
Page
39
of
56
of
TCMTB­
specific
exposure
data.
Limitations
and
uncertainties
associated
with
the
use
of
these
data
include:

 
The
assumption
was
made
that
exposure
patterns
for
workers
at
treatment
facilities
using
DDAC
would
be
similar
to
exposure
patterns
for
workers
at
treatment
facilities
using
TCMTB,
and
therefore
the
exposures
could
be
used
as
surrogate
data
for
workers
that
treat
wood
with
TCMTB.

 
For
environmental
modeling,
it
was
assumed
that
the
leaching
process
from
the
TCMTB
treated
wood
would
be
similar
to
that
of
DDAC.
However,
due
to
the
lack
of
real
data
for
TCMTB­
treated
wood,
it
is
not
possible
to
verify
this
assumption.

 
The
quantities
handled/
treated
were
estimated
based
on
information
from
various
sources,
including
HED's
Standard
Operating
Procedures
(
SOPs)
for
Residential
Exposure
Assessments
(
USEPA
2000,
and
2001)
and
personal
communication
with
experts.
In
particular,
the
use
information
for
the
pulp
and
paper
processing,
oil­
well
uses,
and
cooling
water
tower
uses
are
based
on
personal
communication
with
biocide
manufacturers
for
these
types
of
uses.
The
individuals
contacted
have
experience
in
these
operations
and
their
estimates
are
believed
to
be
the
best
available
without
undertaking
a
statistical
survey
of
the
uses.
In
certain
cases,
no
standard
values
were
available
for
some
scenarios.
Assumptions
for
these
scenarios
were
based
on
AD
estimates
and
could
be
further
refined
from
input
from
registrants.
For
example,
the
quantities
handled/
treated
for
the
application
of
TCMTB
to
the
surface
of
metal/
wood
cooling
towers
could
be
refined.
Page
40
of
56
6.0
REFERENCES
Bestari
KT,
Macey
K,
Soloman
KR,
Tower
N.
1999.
Measurement
and
Assessment
of
Dermal
and
Inhalation
Exposures
to
Didecyl
Dimethyl
Ammonium
Chloride
(
DDAC)
Used
in
the
Protection
of
Cut
Lumber
(
Phase
III).
MRID
455243­
04.

Freeman,
N
,
Jimenez
M,
Reed
KJ,
Gurunathan
S,
Edwards
RD,
Roy
A,
Adgate
JL,
Pellizzari
ED,
Quackenboss
J,
Sexton
K,
Lioy
PJ,
2001.
Quantitative
analysis
of
chilren's
microactivity
patterns:
The
Minnesota
Children's
Pesticide
Exposure
Study.
Journal
of
Exposure
Analysis
and
Environmental
Epidemiology.
11(
6):
501­
509.

HERA,
2005.
Human
and
Environmental
Risk
Assessment,
Guidance
Document
Methodology,
February
2005
(
http://
www.
heraproject.
com).
The
Multi­
Chamber
Concentration
and
Exposure
Model
(
MCCEM)
Model
Version
1.2.
Prepared
for
the
US
EPA
Office
of
Pollution
Prevention
and
Toxics.
Prepared
by
Versar,
Inc.
and
Wilkes
Technologies,
LLC.

USEPA.
1997.
Exposure
Factors
Handbook.
Volume
I­
II.
Office
of
Research
and
Development.
Washington,
D.
C.
EPA/
600/
P­
95/
002Fa.
August
1997.

USEPA.
1998.
PHED
Surrogate
Exposure
Guide.
Estimates
of
Worker
Exposure
from
the
Pesticide
Handler
Exposure
Database
Version
1.1.
Washington,
DC:
U.
S.
Environmental
Protection
Agency.

USEPA.
1999.
Evaluation
of
Chemical
Manufacturers
Association
Antimicrobial
Exposure
Assessment
Study
(
Amended
on
8
December
1992).
Memorandum
from
Siroos
Mostaghimi,
PH.
D.,
USEPA
to
Julie
Fairfax,
USEPA.
Dated
November,
4
1999.
DP
Barcode
D247642.

USEPA.
2000.
Residential
SOPs.
EPA
Office
of
Pesticide
ProgramsBHuman
Health
Effects
Division.
Dated
April
5,
2000.

USEPA.
2001.
HED
Science
Advisory
Council
for
Exposure.
Policy
Update,
November
12.
Recommended
Revisions
to
the
Standard
Operating
Procedures
(
SOPs)
for
Residential
Exposure
Assessment,
February
22,
2001.

Doityourself.
com.
2005.
What
You
Need
to
Know
When
Carpet
Shopping.
http://
doityourself.
com/
carpet/
carpetshopping.
htm,
viewed
September
2005.

USEPA.
2004.
PBT
Profiler:
Assessing
Chemicals
in
the
Absence
of
Data,
v1.203.
http://
www.
pbtprofiler.
net/
default.
asp.
Accessed
January
2006.

USEPA.
2006.
2­(
thiocyanomethylethylthio)
benzothaizole
(
TCMTB)­
report
of
the
Antimicrobials
Division
Toxicity
Endpoint
Selection
Committee
(
ADTC).
Memorandum
from
Timothy
McMahon
to
Deborah
Smegal.
April
4,
2006.
Page
41
of
56
APPENDIX
A:
Master
TCMTB
Label
List
Page
42
of
56
Table
A
shows
the
uses
and
application
rates
stated
on
the
product
labels
for
43
TCMTB
products.
The
table
is
ordered
by
the
type
of
use
associated
with
a
product.
As
any
one
product
may
have
multiple
uses,
products
can
be
listed
multiple
times.
Application
rates,
as
stated
on
the
product
labels,
were
converted
either
into
terms
of
lbs
a.
i./
gal
or
into
terms
of
a
weight
fraction,
in
order
to
more
easily
compare
application
rates
between
products.
All
products
listed
below
are
formulated
as
liquids
(
i.
e.
ready­
to­
use
liquid,
emulsifiable
concentrate,
soluble
concentrate)
except
for
Product
#
1448­
408,
which
is
a
wettable
powder
and
used
only
for
formulation.

Table
A:
Application
Rates
and
Uses
for
TCMTB
Products
Product
Number
Percent
AI
Density
(
lbs/
gal)
Use
App.
Rate
on
Label
Converted
App
Rate
(
Rounded)
Converted
App.
Rate
Units
Comments
1448­
265
30
9
Cutting
Fluids
1250
ppm
a.
i.
0.00125
a.
i.
weight
fraction
for
use
in
diluted
cutting
fluids
1448­
244
10
8.19
Cutting
Fluids
3750
ppm
Product
3.75x10
­
4
a.
i.
weight
fraction
for
use
in
diluted
cutting
fluids
1448­
99
10
8.2
Cutting
Fluids
3750
ppm
Product
3.75x10­
4
a.
i.
weight
fraction
for
use
in
diluted
cutting
fluids
1448­
100
5
7.8
Cutting
Fluids
7500
ppm
Product
3.75x10­
4
a.
i.
weight
fraction
for
use
in
diluted
cutting
fluids
1448­
152
5
7.8
Cutting
Fluids
7500
ppm
Product
3.75x10­
4
a.
i.
weight
fraction
for
use
in
diluted
cutting
fluids
1448­
55
30
9
Cutting
Fluids
1250
ppm
Product
3.75x10­
4
a.
i.
weight
fraction
for
use
in
diluted
cutting
fluids
1448­
150
30
8.7
Cutting
Fluids
1250
ppm
Product
3.75x10­
4
a.
i.
weight
fraction
for
use
in
diluted
cutting
fluids
1448­
386
5
8.5
Cutting
Fluids
7500
ppm
Product
3.75x10­
4
a.
i.
weight
fraction
1448­
151
10
8.19
Cutting
Fluids
750
ppm
Product
7.50x10­
5
a.
i.
weight
fraction
1448­
153
5
7.8
Cutting
Fluids
1500
ppm
Product
7.50x10­
5
a.
i.
weight
fraction
1448­
149
30
9
Cutting
Fluids
250
ppm
Product
7.50x10­
5
a.
i.
weight
fraction
1448­
386
5
8.5
Drilling
Fluids
1.5
Percent
Product
7.50x10­
4
a.
i.
weight
fraction
1448­
99
10
8.2
Drilling
Fluids
0.75
Percent
Product
7.50x10­
4
a.
i.
weight
fraction
50.4
Page
43
of
56
Table
A:
Application
Rates
and
Uses
for
TCMTB
Products
Product
Number
Percent
AI
Density
(
lbs/
gal)
Use
App.
Rate
on
Label
Converted
App
Rate
(
Rounded)
Converted
App.
Rate
Units
Comments
1448­
152
5
7.8
Drilling
Fluids
1.5
Percent
Product
7.50x10­
4
a.
i.
weight
fraction
22.96
1448­
100
5
7.8
Drilling
Fluids
1.5
percent
product
7.50x10­
4
a.
i.
weight
fraction
1448­
153
5
7.8
Drilling
Fluids
1.5
Percent
Product
7.50x10­
4
a.
i.
weight
fraction
1448­
151
10
8.19
Drilling
Fluids
0.75
Percent
Product
7.50x10­
4
a.
i.
weight
fraction
1448­
244
10
8.19
Drilling
Fluids
0.75
Percent
Product
7.50x10­
4
a.
i.
weight
fraction
1448­
150
30
8.7
Drilling
Fluids
0.25
Percent
Product
7.50x10­
4
a.
i.
weight
fraction
1448­
149
30
9
Drilling
Fluids
0.25
Percent
Product
7.50x10­
4
a.
i.
weight
fraction
1448­
55
30
9
Drilling
Fluids
0.25
percent
Product
7.50x10­
4
a.
i.
weight
fraction
1448­
383
4
8.6
Drilling
Fluids
0.8
Percent
Product
3.20x10­
4
a.
i.
weight
fraction
1448­
377
10
9.2
Drilling
Fluids
0.25
Percent
Product
2.50x10­
4
a.
i.
weight
fraction
1448­
376
2.5
8.3
Drilling
Fluids
1
Percent
Product
2.50x10­
4
a.
i.
weight
fraction
1448­
147
10
9
Drilling
Fluids
0.25
Percent
Product
2.50x10­
4
a.
i.
weight
fraction
1448­
148
10
9
Drilling
Fluids
0.25
Percent
Product
2.50x10­
4
a.
i.
weight
fraction
44392­
11
2.5
8.6
Drilling
Fluids
1
Percent
Product
2.50x10­
4
a.
i.
weight
fraction
1448­
81
10
9
Drilling
Fluids
0.25
Percent
Product
2.50x10­
4
a.
i.
weight
fraction
1448­
102
2.5
8.6
Drilling
Fluids
1
Percent
Product
2.50x10­
4
a.
i.
weight
fraction
Page
44
of
56
Table
A:
Application
Rates
and
Uses
for
TCMTB
Products
Product
Number
Percent
AI
Density
(
lbs/
gal)
Use
App.
Rate
on
Label
Converted
App
Rate
(
Rounded)
Converted
App.
Rate
Units
Comments
1448­
172
2.5
8.6
Drilling
Fluids
1
Percent
Product
2.50x10­
4
a.
i.
weight
fraction
1448­
171
2.5
8.6
Drilling
Fluids
1
Percent
Product
2.50x10­
4
a.
i.
weight
fraction
1448­
82
60
10.1
Ion
Exchange
(
Metal
Recovery)
100
ppm
Product
6.00x10­
5
a.
i.
weight
fraction
Twice
a
week
1448­
55
30
9
Leather
0.2
percent
product
6.00x10­
4
a.
i.
weight
fraction
1448­
386
5
8.5
Leather
12
lbs
prod/
1000
lbs
white
weight
stock
6.00x10­
4
a.
i.
weight
fraction
1448­
37
60
0
Leather
1000
ppm
Product
in
Leather
6.00x10­
4
a.
i.
weight
fraction
(
in
leather)

1448­
100
5
7.8
Leather
12
lbs
prod/
1000
lbs
white
weight
stock
6.00x10­
4
a.
i.
weight
fraction
1448­
99
10
8.2
Leather
6
lbs
prod/
1000
lbs
white
weight
stock
6.00x10­
4
a.
i.
weight
fraction
1448­
412
10.4
9
Leather
3000
ppm
Product
3.12x10­
4
a.
i.
weight
fraction
to
white
lime
stock.
1%
mix
to
fatliquor
is
possible
as
well.

1448­
377
10
9.2
Leather
2500
ppm
Product
2.50x10­
4
a.
i.
weight
fraction
1448­
81
10
9
Leather
0.25
Percent
Product
2.50x10­
4
a.
i.
weight
fraction
1448­
102
2.5
8.6
Leather
10
lbs
prod/
1000
lbs
white
weight
stock
2.50x10­
4
a.
i.
weight
fraction
1448­
376
2.5
8.3
Leather
10
lbs
prod/
1000
lbs
white
weight
stock
2.50x10­
4
a.
i.
weight
fraction
1448­
37
60
0
mulch
paper
2.5
lbs/
ton
paper
7.50x10­
4
a.
i.
weight
fraction
1448­
100
5
7.8
Mulch
Paper
30
lbs
prod/
ton
paper
7.50x10­
4
a.
i.
weight
fraction
1448­
82
60
10.1
Oil
Preservation
6
fl
oz
prod/
1000
gal
oil
2.84x10­
4
lbs
a.
i./
gal
Oil
preservation
can
mean
crude,
refined,
and
fuel
preservation
as
well.
Page
45
of
56
Table
A:
Application
Rates
and
Uses
for
TCMTB
Products
Product
Number
Percent
AI
Density
(
lbs/
gal)
Use
App.
Rate
on
Label
Converted
App
Rate
(
Rounded)
Converted
App.
Rate
Units
Comments
1448­
386
5
8.5
Oil
Preservation
32
fl
oz
prod/
1000
gal
oil
1.06x10­
4
lbs
a.
i./
gal
Oil
preservation
can
mean
crude,
refined,
and
fuel
preservation
as
well.

1448­
99
10
8.2
Oil
Preservation
16
fl
oz
prod/
1000
gal
oil
1.03x10­
4
lbs
a.
i./
gal
Oil
preservation
can
mean
crude,
refined,
and
fuel
preservation
as
well.

1448­
100
5
7.8
Oil
Preservation
32
fl
oz
prod/
1000
gal
oil
9.75x10
­
5
lbs
a.
i./
gal
Oil
preservation
can
mean
crude,
refined,
and
fuel
preservation
as
well.

1448­
377
10
9.2
Oil
Preservation
6
fl
oz
prod/
1000
gal
oil
4.31x10­
5
lbs
a.
i./
gal
Oil
preservation
can
mean
crude,
refined,
and
fuel
preservation
as
well.

1448­
81
10
9
Oil
Preservation
6
fl
oz
prod/
1000
gal
oil
4.22x10­
5
lbs
a.
i./
gal
Oil
preservation
can
mean
crude,
refined,
and
fuel
preservation
as
well.

1448­
148
10
9
Oil
Preservation
6
fl
oz
prod/
1000
gal
oil
4.22x10­
5
lbs
a.
i./
gal
Oil
preservation
can
mean
crude,
refined,
and
fuel
preservation
as
well.

1448­
147
10
9
Oil
Preservation
6
fl
oz
prod/
1000
gal
oil
4.22x10­
5
lbs
a.
i./
gal
Oil
preservation
can
mean
crude,
refined,
and
fuel
preservation
as
well.

44392­
11
2.5
8.6
Oil
Preservation
25
fl
oz
prod/
1000
gal
oil
4.20x10­
5
lbs
a.
i./
gal
Oil
preservation
can
mean
crude,
refined,
and
fuel
preservation
as
well.

1448­
102
2.5
8.6
Oil
Preservation
25
fl
oz
prod/
1000
gal
oil
4.20x10­
5
lbs
a.
i./
gal
Oil
preservation
can
mean
crude,
refined,
and
fuel
preservation
as
well.

1448­
172
2.5
8.6
Oil
Preservation
25
fl
oz
prod/
1000
gal
oil
4.20x10­
5
lbs
a.
i./
gal
Oil
preservation
can
mean
crude,
refined,
and
fuel
preservation
as
well.
crude,
refined,
and
fuel
preservation
as
well
1448­
171
2.5
8.6
Oil
Preservation
25
fl
oz
prod/
1000
gal
oil
4.20x10­
5
lbs
a.
i./
gal
Oil
preservation
can
mean
crude,
refined,
and
fuel
preservation
as
well.

1448­
376
2.5
8.3
Oil
Preservation
24
fl
oz
prod/
1000
gal
oil
3.89x10­
5
lbs
a.
i./
gal
Oil
preservation
can
mean
crude,
refined,
and
fuel
preservation
as
well.
Page
46
of
56
Table
A:
Application
Rates
and
Uses
for
TCMTB
Products
Product
Number
Percent
AI
Density
(
lbs/
gal)
Use
App.
Rate
on
Label
Converted
App
Rate
(
Rounded)
Converted
App.
Rate
Units
Comments
1448­
377
10
9.2
Oil
Well
Recovery
13
fl
oz
prod/
1000
gal
H2O
9.34x10­
5
lbs
a.
i./
gal
1448­
81
10
9
Oil
Well
Recovery
13
fl
oz
prod/
1000
gal
H2O
9.14x10­
5
lbs
a.
i./
gal
1448­
148
10
9
Oil
Well
Recovery
13
fl
oz
prod/
1000
gal
H2O
9.14x10­
5
lbs
a.
i./
gal
1448­
147
10
9
Oil
Well
Recovery
13
fl
oz
prod/
1000
gal
H2O
9.14x10­
5
lbs
a.
i./
gal
1448­
102
2.5
8.6
Oil
Well
Recovery
52
fl
oz
prod/
1000
gal
H2O
8.73x10­
5
lbs
a.
i./
gal
1448­
171
2.5
8.6
Oil
Well
Recovery
52
fl
oz
prod/
1000
gal
H2O
8.73x10
­
5
lbs
a.
i./
gal
1448­
172
2.5
8.6
Oil
Well
Recovery
52
fl
oz
prod/
1000
gal
H2O
8.73x10­
5
lbs
a.
i./
gal
44392­
11
2.5
8.6
Oil
Well
Recovery
52
fl
oz
prod/
1000
gal
H2O
8.73x10­
5
lbs
a.
i./
gal
1448­
376
2.5
8.3
Oil
Well
Recovery
52
fl
oz
prod/
1000
gal
H2O
8.43x10­
5
lbs
a.
i./
gal
1448­
55
30
9
Oil
Well
Recovery
3.7
fl
oz
prod/
1000
gal
H2O
7.80x10
­
5
lbs
a.
i./
gal
1448­
149
30
9
Oil
Well
Recovery
3.7
fl
oz
prod/
1000
gal
H2O
7.80x10­
5
lbs
a.
i./
gal
1448­
150
30
8.7
Oil
Well
Recovery
3.7
fl
oz
prod/
1000
gal
H2O
7.54x10­
5
lbs
a.
i./
gal
1448­
386
5
8.5
Oil
Well
Recovery
22.2
fl
oz
prod/
1000
gal
H2O
7.37x10­
5
lbs
a.
i./
gal
Page
47
of
56
Table
A:
Application
Rates
and
Uses
for
TCMTB
Products
Product
Number
Percent
AI
Density
(
lbs/
gal)
Use
App.
Rate
on
Label
Converted
App
Rate
(
Rounded)
Converted
App.
Rate
Units
Comments
1448­
99
10
8.2
Oil
Well
Recovery
11.1
fl
oz
prod/
1000
gal
H2O
7.11x10­
5
lbs
a.
i./
gal
1448­
151
10
8.19
Oil
Well
Recovery
11.1
fl
oz
prod/
1000
gal
H2O
7.10x10­
5
lbs
a.
i./
gal
1448­
244
10
8.19
Oil
Well
Recovery
11.1
fl
oz
prod/
1000
gal
H2O
7.10x10
­
5
lbs
a.
i./
gal
1448­
153
5
7.8
Oil
Well
Recovery
22.2
fl
oz
prod/
1000
gal
H2O
6.76x10­
5
lbs
a.
i./
gal
1448­
100
5
7.8
Oil
Well
Recovery
22.2
fl
oz
prod/
1000
gal
H2O
6.76x10­
5
lbs
a.
i./
gal
1448­
383
4
8.6
Oil
Well
Recovery
10
fl
oz
prod/
1000
gal
H2O
2.69x10­
5
lbs
a.
i./
gal
for
intermittent
feed.
for
continuous
feed,
6.3.
for
slug
feed,
12.6.

1448­
152
5
7.8
Oil
Well
Recovery
7.2
fl
oz
prod/
1000
gal
H2O
2.19x10­
5
lbs
a.
i./
gal
1448­
99
10
8.2
Paint
15
Percent
Product
0.015
a.
i.
weight
fraction
1448­
386
5
8.5
Paint
30
Percent
Product
0.015
a.
i.
weight
fraction
1448­
55
30
9
Paint
5
percent
product
0.015
a.
i.
weight
fraction
1448­
81
10
9
Paint
9
Percent
Product
0.009
a.
i.
weight
fraction
Mold­
resistant
coating
44392­
11
2.5
8.6
Paint
36
Percent
Product
0.009
a.
i.
weight
fraction
1448­
102
2.5
8.6
Paint
36
Percent
Product
0.009
a.
i.
weight
fraction
1448­
376
2.5
8.3
Paint
36
Percent
Product
0.009
a.
i.
weight
fraction
Page
48
of
56
Table
A:
Application
Rates
and
Uses
for
TCMTB
Products
Product
Number
Percent
AI
Density
(
lbs/
gal)
Use
App.
Rate
on
Label
Converted
App
Rate
(
Rounded)
Converted
App.
Rate
Units
Comments
1448­
377
10
9.2
Paint
0.75
Percent
Product
7.50x10­
4
a.
i.
weight
fraction
9%
for
sealant
1448­
383
4
8.6
Papermaking
Chemicals
800
ppm
Product
3.20x10­
5
a.
i.
weight
fraction
in
coating
formulations
for
paper
1448­
55
30
9
Particle
Board
1
percent
product
0.003
a.
i.
weight
fraction
dry
weight
1448­
99
10
8.2
Particle
Board
3
Percent
Product
0.003
a.
i.
weight
fraction
1448­
386
5
8.5
Particle
Board
6
Percent
Product
0.003
a.
i.
weight
fraction
1448­
100
5
7.8
Particle
Board
6
percent
product
0.003
a.
i.
weight
fraction
1448­
81
10
9
Particle
Board
0.3
Percent
Product
3.00x10­
4
a.
i.
weight
fraction
1448­
377
10
9.2
Particle
Board
0.3
Percent
Product
3.00x10­
4
a.
i.
weight
fraction
1448­
45
8
9.6
Process
Fresh
Water
4
ppm
Product
3.20x10­
7
a.
i.
weight
fraction
1448­
383
4
8.6
Process
Fresh
Water
8
ppm
Product
3.20x10­
7
a.
i.
weight
fraction
1448­
386
5
8.5
Pulp
Preservation
30
lbs
prod/
ton
paper
7.50x10­
4
a.
i.
weight
fraction
1448­
100
5
7.8
Pulp
Preservation
24
lbs
prod/
ton
paper
6.00x10­
4
a.
i.
weight
fraction
1448­
99
10
8.2
Pulp
Preservation
12
lbs
prod/
ton
paper
6.00x10­
4
a.
i.
weight
fraction
for
agricultural
mulch
paper,
15
lbs/
ton
1448­
37
60
0
pulp
preservation
2
lbs/
ton
6.00x10­
4
a.
i.
weight
fraction
ton
dry
fiber
1448­
55
30
9
Pulp
Preservation
2
lbs/
ton
3.00x10­
4
a.
i.
weight
fraction
dry
fiber
1448­
81
10
9
Pulp
Preservation
4
lbs
prod/
ton
paper
2.00x10­
4
a.
i.
weight
fraction
for
wet
lap
or
sheet
pulp.
for
bacteriostatic
paper,
9.0%
addition.

1448­
377
10
9.2
Pulp
Preservation
1.5
lbs
prod/
ton
paper
7.50x10­
5
a.
i.
weight
fraction
9%
for
bacteriostatic
paper
Page
49
of
56
Table
A:
Application
Rates
and
Uses
for
TCMTB
Products
Product
Number
Percent
AI
Density
(
lbs/
gal)
Use
App.
Rate
on
Label
Converted
App
Rate
(
Rounded)
Converted
App.
Rate
Units
Comments
1448­
383
4
8.6
Pulp
Preservation
2
lbs
prod/
ton
paper
4.00x10­
5
a.
i.
weight
fraction
1448­
376
2.5
8.3
Pulp
Preservation
2
lbs
prod/
ton
paper
2.50x10­
5
a.
i.
weight
fraction
1448­
102
2.5
8.6
Pulp
Preservation
2
lbs
prod/
ton
paper
2.50x10­
5
a.
i.
weight
fraction
1448­
45
8
9.6
Pulp
Preservation
0.6
lbs
prod/
ton
paper
2.40x10­
5
a.
i.
weight
fraction
400
ppm
to
coating
formulations
1448­
3681
30
9
Pulp
Preservation
0.1
lbs
prod/
1000
ft2
0.00488
a.
i.
weight
fraction
For
soapwrap
application.
(
0.1
lb
product/
1000
ft2)
/
(
0.0205
lbs/
ft2)

1448­
55
30
9
Sapstain
Control
0.08
gal
prod/
gal
H2O
0.216
lbs
a.
i./
gal
dipping
solution
1448­
386
5
8.5
Sapstain
Control
480
gal
prod/
1000
gal
H2O
0.204
lbs
a.
i./
gal
1448­
99
10
8.2
Sapstain
Control
240
gal
prod/
1000
gal
H2O
0.197
lbs
a.
i./
gal
1448­
100
5
7.8
Sapstain
Control
0.48
gal
prod/
gal
H2O
0.187
lbs
a.
i./
gal
dipping
solution
1448­
341
5
7.6
Sapstain
Control
100
Percent
Product
0.05
a.
i.
weight
fraction
can
be
used
straight
as
a
water
repellant
(
not
sapstain)
for
millwork,
shingles,
structural
lumber,
etc.
in
above
ground
service.
Use
inline
application.

1448­
376
2.5
8.3
Sapstain
Control
960
lbs
prod/
1000
gal
H2O
0.024
lbs
a.
i./
gal
1448­
377
10
9.2
Sapstain
Control
180
lbs
prod/
1000
gal
H2O
0.018
lbs
a.
i./
gal
1448­
81
10
9
Sapstain
Control
180
lbs
prod/
1000
gal
H2O
0.018
lbs
a.
i./
gal
1448­
393
1
7.2
Sapstain
Control
100
Percent
Product
0.01
a.
i.
weight
fraction
to
be
used
in
inline
application
for
water
repellant.

1448­
102
2.5
8.6
Sapstain
Control
96
lbs
prod/
1000
gal
H2O
0.0024
lbs
a.
i./
gal
Page
50
of
56
Table
A:
Application
Rates
and
Uses
for
TCMTB
Products
Product
Number
Percent
AI
Density
(
lbs/
gal)
Use
App.
Rate
on
Label
Converted
App
Rate
(
Rounded)
Converted
App.
Rate
Units
Comments
1448­
55
30
9
Textile
2
percent
product
0.006
a.
i.
weight
fraction
1448­
55
30
9
Wastewater
30
ppm
Product
9.00x10­
6
a.
i.
weight
fraction
1448­
37
60
0
wood
chip
preservation
1
lbs/
ton
3.00x10­
4
a.
i.
weight
fraction
ton
dry
wood
1Product
#
1448­
368
states
that
the
product
is
to
be
applied
at
a
rate
0.1
lbs
prod/
1,000
ft2
for
soap
wrap.
Without
knowing
the
weight
of
soapwrap
(
in
lbs/
ft2),
the
application
rate
cannot
be
converted
into
terms
that
allow
for
comparison
with
other
products.
For
lack
of
information,
it
was
assumed
that
soap
wrap
has
a
weight
density
of
100
grams/
m2,
or
0.0205
lbs/
ft2.
Page
51
of
56
APPENDIX
B:
Summary
of
CMA
and
PHED
Data
Page
52
of
56
Chemical
Manufacturers
Association
(
CMA)
Data:
In
response
to
an
EPA
Data
Call­
In
Notice,
a
study
was
undertaken
by
the
Institute
of
Agricultural
Medicine
and
Occupational
Health
of
The
University
of
Iowa
under
contract
to
the
Chemical
Manufacturers
Association.
In
order
to
meet
the
requirements
of
Subdivision
U
of
the
Pesticide
Assessment
Guidelines
(
superseded
by
Series
875.1000­
875.1600
of
the
Pesticide
Assessment
Guidelines),
handler
exposure
data
are
required
from
the
chemical
manufacturer
specifically
registering
the
antimicrobial
pesticide.
The
applicator
exposure
study
must
comply
with
the
assessment
guidelines
for
AApplicator
Exposure
Monitoring@
in
Subdivision
U
and
the
AOccupational
and
Residential
Exposure
Test
Guidelines@
in
Series
875.
For
this
purpose,
CMA
submitted
a
study
on
28
February,
1990,
entitled
"
Antimicrobial
Exposure
Assessment
Study
(
amended
on
December
8,
1992)"
which
was
conducted
by
William
Popendorf,
et
al.
It
was
evaluated
and
accepted
by
Occupational
and
Residential
Exposure
Branch
(
OREB)
of
Health
Effect
Division
(
HED),
Office
of
Pesticides
Program
(
OPP)
of
EPA
in
1990.
The
purpose
of
this
CMA
study
was
to
characterize
exposure
to
antimicrobial
chemicals
in
order
to
support
pesticide
re­
registrations
(
CMA,
1992).
The
unit
exposures
presented
in
the
most
recent
EPA
evaluation
of
the
CMA
database
(
USEPA,
1999b)
was
used
in
this
assessment.

The
Agency
determined
that
the
CMA
study
had
fulfilled
the
basic
requirements
of
Subdivision
U
­
Applicator
Exposure
Monitoring.
The
advantages
of
CMA
data
over
other
Asurrogate
data
sets@
is
that
the
chemicals
and
the
job
functions
of
mixer/
loader/
applicator
were
defined
based
on
common
application
methods
used
for
antimicrobial
pesticides.
A
few
of
the
deficiencies
in
the
CMA
data
are
noted
below:

 
The
inhalation
concentrations
were
typically
below
the
detection
limits,
so
the
unit
exposures
for
the
inhalation
exposure
route
could
not
be
accurately
calculated.
 
QA/
QC
problems
including
lack
of
either/
or
field
fortification,
laboratory
recoveries,
and
storage
stability
information.
 
Data
have
an
insufficient
amount
of
replicates.

The
Pesticide
Handlers
Exposure
Database
(
PHED):
The
Pesticide
Handlers
Exposure
Database
(
PHED)
has
been
developed
by
a
Task
Force
consisting
of
representatives
from
Health
Canada,
the
U.
S.
Environmental
Protection
Agency
(
EPA),
and
the
American
Crop
Protection
Association
(
ACPA).
PHED
provides
generic
pesticide
worker
(
i.
e.,
mixer/
loader
and
applicator)
exposure
estimates.
The
dermal
and
inhalation
exposure
estimates
generated
by
PHED
are
based
on
actual
field
monitoring
data,
which
are
reported
generically
(
i.
e.,
chemical
specific
names
not
reported)
in
PHED.
It
has
been
the
Agency=
s
policy
to
use
Asurrogate@
or
Ageneric@
exposure
data
for
pesticide
applicators
in
certain
circumstances
because
it
is
believed
that
the
physical
parameters
(
e.
g.,
packaging
type)
or
application
technique
(
e.
g.,
aerosol
can),
not
the
chemical
properties
of
the
pesticide,
attribute
to
exposure
levels.
[
Note:
Vapor
pressures
for
the
chemicals
in
PHED
are
in
the
range
of
E­
5
to
E­
7
mm
Hg.]
Chemical
specific
properties
are
accounted
for
by
correcting
the
exposure
data
for
study
specific
field
and
laboratory
recovery
values
as
specified
by
the
PHED
grading
criteria.

PHED
handler
exposure
data
are
generally
provided
on
a
normalized
basis
for
use
in
exposure
assessments.
The
most
common
method
for
normalizing
exposure
is
by
pounds
of
active
ingredient
(
ai)
handled
per
replicate
(
i.
e.,
exposure
in
mg
per
replicate
is
divided
by
the
amount
of
ai
handled
in
that
particular
replicate).
These
unit
exposures
are
expressed
as
mg/
lb
ai
Page
53
of
56
handled.
This
normalization
method
presumes
that
dermal
and
inhalation
exposures
are
linear
based
on
the
amount
of
active
ingredient
handled.
Page
54
of
56
APPENDIX
C:
Calculation
of
DDAC
Unit
Exposure
Values
Page
55
of
56
Table
C­
1:
DDAC
Dermal
and
Inhalation
Exposure
Values
for
Chemical
Operators,
Graders,
Millwrights,
Clean­
up
Crews,
and
Trim
Saw
Operatorsa
Chemical
Operator
Grader
Trim
Saw
Operator
Millwright
Cleanup
Crew
Dermal
Inhalation
Dermal
Inhalation
Dermal
Inhalation
Dermal
Inhalation
Dermal
Inhalation
Replicate
Number
Potential
exposure
(
mg)
Air
Concentrationb,

c
(:
g/
m3)
Potential
exposured
(
mg)
Potential
exposure
(
mg)
Air
Concentration
b,
c
(:
g/
m3)
Potential
exposure
d
(
mg)
Potential
exposure
(
mg)
Air
Concentration
b,
c
(:
g/
m3)
Potential
exposure
d
(
mg)
Potential
exposure
(
mg)
Air
Concentration
b,
c
(:
g/
m3)
Potential
exposure
d
(
mg)
Potential
exposure
(
mg)
Air
Concentration
b,
c
(:
g/
m3)
Potential
exposure
d
(
mg)

1
3.5
10.1
0.0808
3.05
2.90
0.0232
0.78
2.83
0.0227
1.31
2.92
0.0233
68.3
2.99145
0.0239
2
6.11
2.80
0.0224
7.47
2.93
0.0234
1.98
12.3
0.0984
29.08
2.83
0.0226
0.720
2.78840
0.0223
3
6.07
2.79
0.0223
1.09
2.91
0.0233
8.03
15.6
0.1248
166
30.3
0.2424
4
46.37
2.82
0.0226
10.51
3.00
0.0240
95.2
412
3.2960
5
0.94
2.93
0.0235
0.61
2.82
0.0226
1.20
2.83585
0.0227
6
22.15
2.83
0.0227
0.98
2.85
0.0228
0.260
2.80989
0.0225
7
21.45
2.77
0.0222
2.63
2.91
0.0233
8
0.22
2.73
0.0218
5.23
2.85
0.0228
9
0.44
2.77
0.0222
0.19
13.20
0.1056
10
0.33
3.14
0.0251
1.47
2.89
0.0231
11
0.29
2.88
0.0230
2.38
2.85
0.0228
12
4.09
2.81
0.0225
13
1.03
2.94
0.0235
Arithmetic
Mean
9.81
3.51
0.0281
3.13
3.68
0.0295
1.38
7.57
0.061
12.8
7.12
0.057
55.3
75.6
0.60
Minimum
0.22
2.73
0.0218
0.19
2.81
0.0225
0.78
2.83
0.0227
1.31
2.83
0.0226
0.260
2.79
0.0223
Maximum
46.4
10.1
0.081
10.51
13.2
0.106
1.98
12.3
0.098
29.1
15.6
0.125
166
412
3.30
a.
"
Measurement
and
Assessment
of
Dermal
and
Inhalation
Exposures
to
Didecyl
Dimethyl
Ammonium
Chloride
(
DDAC)
Used
in
the
Protection
of
Cut
Lumber
(
Phase
III)"
is
the
study
that
values
were
obtained
from
for
this
table
(
Bestari
et
al.,
1999,
MRID
455243­
04).

b.
The
inhalation
LOD
was
not
provided
for
chemical
operators,
graders,
trim
saw
operators,
millwrights,
or
the
clean­
up
crew.
Therefore,
the
LOD
provided
for
the
diptank
operator
(
5.6
:
g)

was
used
for
these
positions.
Residues
less
than
the
LOD
were
adjusted
to
1/
2
LOD.

c.
The
inhalation
limit
of
detection
was
converted
to
:
g/
m3
using
the
following
equation:
air
concentration
(:
g/
m3)
=
5.6
:
g/
[
average
flow
rate
(
L/
min)
*
sampling
duration
(
480
min)
*
1000
L/
m3.
Data
was
obtained
from
Bestari
et
al
(
1999).

d.
DDAC
air
concentrations
were
converted
to
inhalation
exposure
using
the
following
equation:
Air
concentration
(:
g/
m3)
x
inhalation
rate
(
1.0
m3/
hr)
x
Conversion
factor
(
1
mg/
1000
:
g)
x
sample
duration
(
8
hours/
day
Page
56
of
56
Table
C­
2:
Normalization
of
DDAC
Dermal
and
Inhalation
Exposure
Values
for
Diptank
Operatorsa
Worker
ID
Mill
number
Sample
Time
(
min)
DDAC
Conc.
in
Diptank
(%)
Gloves
Dermal
Body
Exposureb
(
mg)
Hand
Exposureb
(
mg)
Total
Dermal
Exposure
(
mg)
Normalized
Total
Dermal
Unit
Exposurec
(
mg/
1
%
solution)
Air
Conc.
d
(
mg/
m3)
Inhalation
Exposuree
(
mg)
Normalized
Inhalation
Unit
Exposurec
(
mg
/
1%
solution)

M7P1A
7
480
0.64
Rubber
0.5
3.44
3.94
6.16
0.003
0.024
0.0375
M7P1B
7
480
0.64
Rubber
0.32
2.02
2.34
3.66
0.003
0.024
0.0375
M8P4A
8
408
0.42
Rubber
0.04f
1.34
1.38
3.29
0.003
0.024
0.057
M8P4B
8
480
0.42
Rubber
0.04f
0.5
0.54
1.29
0.003
0.024
0.057
M8P7
8
480
0.42
Cotton
0.03
0.04
0.07
0.17
0.003
0.024
0.057
M11P9A
11
395
0.63
Leather
0.15
3.33
3.48
5.52
0.003
0.024
0.0381
M11P9B
11
480
0.63
Leather
0.1
0.45
0.55
0.87
0.003
0.024
0.0381
Arithmetic
Mean
0.17
1.59
1.76
2.99
0.0030
0.0240
0.046
Standard
Deviation
0.18
1.39
1.53
2.32
0.0000
0.0000
0.0103
Median
0.10
1.34
1.38
3.29
0.0030
0.0240
0.0381
Geometric
Mean
0.10
0.83
0.99
1.86
0.0030
0.0240
0.045
90%
tile
0.39
3.37
3.66
5.78
0.0030
0.0240
0.057
Maximum
0.50
3.44
3.94
6.16
0.0030
0.0240
0.057
a.
"
Measurement
and
Assessment
of
Dermal
and
Inhalation
Exposures
to
Didecyl
Dimethyl
Ammonium
Chloride
(
DDAC)
Used
in
the
Protection
of
Cut
Lumber
(
Phase
III)"
is
the
study
that
values
were
obtained
from
for
this
table
(
Bestari
et
al.,
1999,
MRID
455243­
04).

b.
DDAC
concentration
that
was
detected
in
the
monitoring
study
(
MRID
#
455243­
04).

c.
Normalization
of
DDAC
data
for
percent
ai
treatment.
Normalized
Unit
Exposure
(
mg/
1%
ai
solution)
=
Exposure
(
mg
DDAC)
/
concentration
in
diptank
solution
(%
DDAC)

d.
All
inhalation
residues
were
<
LOD
(
5.6
µ
g
or
0.0056
mg/
m3).
1/
2
LOD
was
used
in
all
calculations
(
0.003
mg/
m3).
Air
Concentration
(
mg/
m3)
=
5.6
µ
g
/
(~
2
L/
min
flow
rate
x
~
480
min)

x
1000
L/
m3
conversion
x
0.001
µ
g/
mg
=
0.003
mg/
m3
e.
Inhalation
exposure
(
mg)
=
air
concentration
(
mg/
m3)
x
inhalation
rate
(
1.0
m3/
hr)
x
sample
duration
(
8
hours/
day).

f.
Residues
were
<
LOD
for
dermal
samples
M8P4A,
M8P4B.
Sample
size
of
~
11,231
cm2
x
<
0.007
ug/
cm2
=
LOD
of
0.079
mg.
1/
2
LOD
reported
(
i.
e.,
0.04
mg)
